Bankr. M.D. Pennsylvania cuts bankruptcy fee award 35.2%, including for clerical work

What happened

The fee applicant in the bankruptcy matter requested $3,409. The court awarded $2,209, a reduction of $1,200, or 35.2%. The court reduced the award because some charges were for non-billable administrative tasks and paralegal or secretarial duties that should have been billed at non-attorney rates, and because certain tasks were billed for excessive time. The court found that two hours of attorney time at most, including overhead for staff, should have been billed to this unopposed matter.

What the court said

a reduction in the amount of allowed compensation is necessary due to charges for services that are non-billable administrative tasks, paralegal or secretarial duties that should have been billed at non-attorney rates

The court also reduced the award for: excessive hours, excessive hours.

Why it matters

The ruling shows that courts will reduce fee awards when time records do not separate clerical or administrative tasks from legal work, and when entries reflect more time than a task reasonably required. It underscores that the description of each time entry affects whether the rate and hours claimed will be allowed.

How to keep this out of your fee petition

• Leave purely clerical work off the fee petition.
• Describe paralegal tasks so the substantive work is clear.
• Split mixed entries into their substantive and clerical parts.

Cite this ruling

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.