D. Arizona cuts commercial fee award 1.3% over block billing | LegalTime AI

D. Arizona cuts commercial fee award 1.3% over block billing

Kivalu v. Carrington Mortgage Servicer LLC et al, No. 2:25-cv-04221. District Court, D. Arizona, Judge Michael T Liburdi. Decided . Read the opinion

Requested
$6,930
Awarded
$6,840
Cut
1.3%$90

Commercial · Contract fee clause

What happened

The fee applicant sought $6,930 in fees under a contract fee clause, covering 23.1 hours. The court awarded $6,840, a reduction of $90, or 1.3%. The court applied a 20% reduction to the December 22, 2025 time entry for block billing, because it could not determine how much time was spent preparing the brief versus sending the brief to the client. The figures do not include costs.

What the court said

Block billing · 20% reduction
The Court will reduce by 20% the December 22, 2025 time entry for improper block billing because the Court could not determine how much time was spent on preparing the brief versus sending the brief to counsel's client

Why it matters

The ruling shows that a single block-billed entry can draw a percentage cut even in a small fee request, and that the reduction is limited to the affected entry rather than the whole award. It also shows courts will reduce fees when an entry does not separate distinct tasks.

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

Kivalu v. Carrington Mortgage Servicer LLC, No. 2:25-cv-04221 (D. Ariz. Apr. 7, 2026)

See hourly rates the D. Arizona approves and attorney fee motions in Arizona 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.

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