E.D. Pennsylvania cuts immigration fee award 0.6% over clerical work | LegalTime AI

E.D. Pennsylvania cuts immigration fee award 0.6% over clerical work

MAKE THE ROAD STATES INC et al v. HARRAN et al, No. 2:25-cv-02938. District Court, E.D. Pennsylvania, Judge Juan R. Sánchez. Decided . Read the opinion

Requested
$35,170
Awarded
$34,953
Cut
0.6%$217

Immigration

What happened

The fee applicant in an immigration case sought $35,170 for 69.4 hours. Judge Juan R. Sánchez awarded $34,953, a reduction of $217 or 0.6%. The court reduced attorney Armstrong's time by 0.3 hours and paralegal Hoecker's time by 0.6 hours because entries reflected time spent filing or performing administrative tasks. The figures do not include costs.

What the court said

Clerical work billed as legal work
There are entries for attorney Armstrong and paralegal Hoecker which reflect time spent filing or performing administrative tasks. Accordingly, attorney Armstrong’s time will be reduced by 0.3 hours
Clerical work billed as legal work
paralegal Hocker’s time will be reduced by 0.6 hours, as reflected in the table below

Why it matters

The order shows that courts review individual time entries and will trim hours for tasks that are clerical rather than legal, even when the overall reduction is small. It illustrates that fee petitions are examined line by line, and that administrative entries can be separated from compensable attorney and paralegal work.

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

MAKE THE ROAD STATES INC v. HARRAN, No. 2:25-cv-02938 (E.D. Pa. Apr. 22, 2026)

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