E.D. New York cuts wage and hour fee award 42.7%, including for block billing

What happened

The plaintiffs in a Fair Labor Standards Act case requested $66,366 in attorney fees. The court awarded $38,006.25, a reduction of $28,359.75 or 42.7%. It lowered the requested hourly rates, including for Mr. Kim and for Ms. Choi. It also excluded entries that were block billed or did not distinguish work on the corporate defendant from work on the individual defendants, and hours billed for improper and incomplete filings.

What the court said

The records appear to suggest "block-billing"—a practiced "frowned upon [] since it amounts to 'the lumping together of discrete tasks with others that are not clearly defined'

The court also reduced the award for: hourly rate reduced, hourly rate reduced, hourly rate reduced, unrelated claims, other.

Why it matters

The ruling shows that a fee award can be reduced on several fronts at once: hourly rates, block-billed entries, entries mixing claims against different defendants, and time spent on filings the court found improper. It illustrates how closely courts examine time records and whether each entry ties to compensable work.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the E.D. New York approves and attorney fee motions in New York federal courts.

Figures and quotes are taken from the opinion and checked against its text. Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.