S.D. Florida cuts civil rights fee award, including for vague entries

What happened

Gelber Schachter & Greenberg, P.A. sought fees under 42 U.S.C. § 1988 in a civil rights case. The court did not state totals. It excluded 5.2 hours of vague entries that said only follow up on or review and analyze, finding they did not show the attorney's contribution. It awarded all hours of one attorney but not another's time on the same tasks, and split the hours of two other attorneys to account for duplicative efforts.

What the court said

Many of his entries provide only the vague description of “follow up on” issues regarding the motion for fees (or “review and analyze”). Collectively, none of his time entries are sufficient for me to understand his contribution to this part of the litigation, and I have not included his time in the calculation.

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

Why it matters

The ruling shows that courts will exclude time entries too vague to show what work was done, and will reduce hours for duplicative staffing even without line-by-line cuts. Attorneys seeking fees must keep records that let the court understand each timekeeper's contribution.

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 S.D. Florida approves and attorney fee motions in Florida 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.