E.D. New York cuts wage and hour fee award 18.4%, including for vague entries

What happened

Anderson Dodson, P.C. sought $17,178.50 in fees under the Fair Labor Standards Act for 73 hours. The court awarded $14,009.50, a reduction of $3,169.00 or 18.4%. It lowered hourly rates for Jess Velez, Jessica Balint and Billy Hernandez, excluded a blank 0.2-hour entry by Balint, and assigned a reduced hourly rate to 11.7 hours of clerical tasks billed as legal work. The figures do not include costs.

What the court said

the Court completely excludes entirely the blank entry submitted by Balint (0.2 hours)

assigns a $45.00 hourly rate to all of the aforementioned clerical tasks (11.7 hours)

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

Why it matters

The ruling shows that courts will reduce rates and exclude entries that are blank or describe clerical tasks, and that time records must identify the work performed and the person who performed it for the hours to be compensable at requested rates.

How to keep this out of your fee petition

• Name the task, the document or person involved, and the purpose.
• Avoid stock phrases that could describe any day in any matter.
• Keep privileged detail general, but specific enough to show the work.

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.