M.D. Tennessee cuts intellectual property fee award 12%, including for vague entries | LegalTime AI

M.D. Tennessee cuts intellectual property fee award 12%, including for vague entries

Livingston v. Jay Livingston Music, Inc., et al., No. 3:22-cv-00532. District Court, M.D. Tennessee, Judge Waverly D. Crenshaw, Jr.. Decided . Read the opinion

Requested
$385,979.05
Awarded
$339,661.56
Cut
12%$46,317.49

Intellectual property · Fee applicant's counsel: Loeb & Loeb LLP

What happened

Loeb & Loeb LLP, counsel for the fee applicant, sought $385,979.05 in fees in this copyright case. Judge Waverly D. Crenshaw, Jr. awarded $339,661.56, a reduction of $46,317.49, or 12%. The court applied a single 12% cut to the total fee, citing vague descriptions, overlapping work by two firms, the parties' shared responsibility for litigation expense, the complexity of the case, and Tammy's financial circumstances. The figures do not include costs.

What the court said

Vague entries · 12% reduction · $46,317.49
A 12% reduction compensates Defendants for the necessary work performed while accounting for vague descriptions, overlapping work by two firms, the parties’ shared responsibility for litigation expense, the complexity of the case, and Tammy’s financial circumstances.

The court also reduced the award for: duplicative staffing, other.

Why it matters

The ruling shows that a court may apply one across-the-board percentage cut to the total fee when time records contain vague descriptions and overlapping work, rather than striking specific entries. It also shows that recordkeeping problems can be weighed alongside other factors in a single reduction.

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

Livingston v. Jay Livingston Music, Inc., No. 3:22-cv-00532 (M.D. Tenn. Sept. 28, 2026)

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