D. Massachusetts cuts fee award 24.3%, including for reconstructed time

What happened

The plaintiffs sought $18,100 in sanctions fees. The court awarded $13,695, a reduction of $4,405. It applied a $615 discount for a baseline calculation error, cut a September 3 entry from 0.4 to 0.2 hours ($90) because a 7-minute call could not support 24 minutes of billable time, disallowed $1,950 for drafting a sanctions motion on unrelated claims, and disallowed $1,500 for 3 hours of reconstructed time for a fee hearing the court found unnecessary.

What the court said

Because this Court has determined that a supplementary hearing on fees is unnecessary and resolves this matter strictly on the moving papers, these speculative hours are disallowed.

The court also reduced the award for: other, excessive hours, unrelated claims.

Why it matters

The ruling shows that courts will reduce fee awards for entries that do not match the underlying task, for time spent on unsuccessful or unrelated matters, and for hours reconstructed for work the court did not require. Each category was priced and deducted separately.

How to keep this out of your fee petition

• Track time from the first day, even in matters you expect to be contingent or fee-shifting.
• If you must reconstruct time, say so and explain the sources.
• Do not round or estimate to fill gaps.

Cite this ruling

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