W.D. Pennsylvania cuts consumer protection fee award 12.6%, including for clerical work

What happened

Centennial Law Offices sought $12,313.25 in fees under the Fair Debt Collection Practices Act. The court awarded $10,768.25, a reduction of $1,545. It cut 1.08 paralegal hours billed for administrative tasks such as opening a file and mailing a demand letter, and reduced 6.66 hours claimed for preparing the fee motion to 3 hours, citing duplication and overlap in the memoranda.

What the court said

Time spent on administrative tasks as opposed to legal work: “Process initial intake report/initiate representation/create file” (paralegal): .75 hours at $75.00 per hour: $56.25. “Mailing 3 of demand letter to Defendant/update file” (paralegal): .33 hours at $75.00 per hour: $24.75.

The court also reduced the award for: excessive hours.

Why it matters

The ruling shows courts separate administrative tasks from legal work when reviewing time records, and scrutinize hours spent on the fee motion itself. Entries describing file setup and mailing can be trimmed 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 W.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.