Sixth Circuit cuts employment fee award 77.7%, including for vague entries

What happened

The plaintiff's lawyer sought $1,509,613.50 in Title VII fees for 2,418.9 hours. The district court selected a fixed hourly rate, denied payment for 500.2 hours on unrelated claims, cut the remaining hours by 50% as excessive, and applied a further 10% reduction because the hours were not clearly segregated. The Sixth Circuit affirmed, leaving an award of $337,320 for 937 hours, a reduction of $1,172,293.50, or 77.7%.

What the court said

But Curhan's failure to segregate more clearly the hours he billed is enough to support the 10% reduction.

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

Why it matters

The ruling shows that appellate courts will defer to district courts that trim fee requests for vague or unsegregated time entries, even when that is only one of several reductions. It also confirms that a 10% cut can rest on a lawyer's failure to separate billable work clearly, without a line-by-line review.

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

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.