D. Hawaii cuts consumer protection fee award over clerical work
Lakaeva v. Mockingbird Tiny Homes LLC, No. 1:22-cv-00424. District Court, D. Hawaii, Judge Kenneth J. Mansfield. Decided . Read the opinion
The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.
Consumer protection · Fee applicant's counsel: Schlack Ito
What happened
Schlack Ito, counsel for the fee applicant in a consumer protection case, sought attorney fees. The court did not state totals for the request or the award. It deducted 3.4 hours that it found were billed for clerical tasks rather than legal work: 0.4 hours of Mr. Kobayashi's time, 1.7 hours of Ms. Wu's time, and 1.3 hours of Ms. Ham's time. The court applied no other reductions.
What the court said
the following deductions are appropriate for clerical tasks: 0.4 hours of Mr. Kobayashi's time, 1.7 hours of Ms. Wu's time, and 1.3 hours of Ms. Ham's time
Why it matters
The ruling shows that courts separate clerical tasks from legal work when reviewing time records on a fee petition, and that hours billed for clerical tasks are deducted even when the overall request is otherwise supported.
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
Lakaeva v. Mockingbird Tiny Homes LLC, No. 1:22-cv-00424 (D. Haw. Oct. 30, 2024) See hourly rates the D. Hawaii approves and attorney fee motions in Hawaii 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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