E.D. Pennsylvania cuts wage and hour fee award, including for vague entries

What happened

The plaintiffs sought sanctions fees in a wage and hour case. The court excluded time tied to unrelated activities, including two depositions and part of a third, and struck entries it found too vague to assess. It also excluded clerical work, including 16 hours for trial binders, and limited conferences to one hour, deposition attendance and preparation to the attorneys who took or defended the depositions, and events to two timekeepers. It cut 31.5 hours of deposition preparation to 8, 21.9 hours on one day to 8, and four hours of notice preparation to 1.

What the court said

Thus, I will exclude the time for entries like these, and others, that are “nowhere near specific enough.”

However, there are some entries that appear to be purely clerical in nature, and Plaintiffs may not recover fees for that time.

I will exclude the 16 hours that Santiago Kling billed to prepare trial binders

The court also reduced the award for: unrelated claims, excessive hours, duplicative staffing, duplicative staffing, excessive hours, limited success, excessive hours, other, excessive hours.

Why it matters

The ruling shows that a fee petition stands or falls on the detail in each time entry. Entries too vague to show what was done are excluded, clerical tasks are not compensable as legal work, and courts will trim hours for duplication and excess even where the underlying work was necessary.

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. 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.