E.D. Louisiana cuts wage and hour fee award 7.5%, including for clerical work | LegalTime AI

E.D. Louisiana cuts wage and hour fee award 7.5%, including for clerical work

Moore v. MW Servicing, LLC, et al, No. 2:20-cv-00217. District Court, E.D. Louisiana, Judge Michael B. North. Decided . Read the opinion

Requested
$159,225
Awarded
$147,245
Cut
7.5%$11,980

Wage and hour · Fair Labor Standards Act · Fee applicant's counsel: Stiegler Law Firm, L.L.C.

What happened

The Stiegler Law Firm, L.L.C. sought $159,225 in attorney fees under the Fair Labor Standards Act. The court reduced the proposed hourly rate slightly, excluded 3.5 hours for work on conditional certification and communications with an opt-in plaintiff that did not contribute to the individual plaintiffs' claims, and disallowed 0.4 hours as clerical, lowering billed hours from 240.3 to 239.9. The court awarded $147,245, a reduction of $11,980 or 7.5%.

What the court said

Clerical work billed as legal work
only the 0.4 hours identified are disallowed as clerical, bringing Stiegler’s hours down from 240.3 to 239.9

The court also reduced the award for: hourly rate reduced, unrelated claims.

Why it matters

The ruling shows that courts will separate clerical tasks from legal work when reviewing time records, even when the clerical portion is small. It also shows that entries tied to claims outside the individual plaintiffs' case can be excluded, and that a requested hourly rate may be adjusted downward.

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

Moore v. MW Servicing, LLC, No. 2:20-cv-00217 (E.D. La. Nov. 12, 2024)

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

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