E.D. Texas cuts commercial fee award 12.5%, including for clerical work

What happened

MidFirst Bank sought $2,640 in attorney fees under a contract fee clause. The court awarded $2,310, a reduction of $330. It cut 1.8 hours of clerical work that had been billed as legal work. It also denied 9.2 requested paralegal hours, finding the bank had not carried its burden to show that the paralegal award was reasonable.

What the court said

Accordingly, the court finds an appropriate reduction of time in the amount of 1.80 hours.

The court also reduced the award for: other.

Why it matters

The ruling shows courts separate clerical tasks from legal work when reviewing time records, and that a fee applicant must support paralegal hours with enough detail to show they are reasonable. Unsupported entries can be denied even when the overall request is modest.

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

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