W.D. Pennsylvania cuts ERISA benefits fee award 0.8%, including for clerical work | LegalTime AI

W.D. Pennsylvania cuts ERISA benefits fee award 0.8%, including for clerical work

MULLINS v. THE CONSOL ENERGY, INC. LONG TERM DISABILITY PLAN, No. 2:20-cv-01883. District Court, W.D. Pennsylvania, Judge J. Nicholas Ranjan. Decided . Read the opinion

Requested
$243,568.50
Awarded
$241,746
Cut
0.8%$1,822.50

ERISA benefits · ERISA

What happened

The plaintiff sought $243,568.50 in attorney fees under ERISA. The court awarded $241,746, a reduction of $1,822.50. It cut 5.4 hours ($3,240) for time entries after the brief was filed, halved two hours for reviewing routine filings ($600), reduced 4.6 hours ($2,760) for administrative tasks billed as legal work, halved 8.8 hours of legal research ($2,640), and accepted a two-hour deduction ($1,290) for attendance at mediation.

What the court said

Clerical work billed as legal work · $2,760
the Court will reduce the fee award by 4.6 hours/$2,760 as to the administrative tasks.

The court also reduced the award for: excessive hours, excessive hours, excessive hours, duplicative staffing.

Why it matters

The ruling shows that courts will separate clerical tasks from legal work and reduce fees for time entries that do not reflect legal judgment, even when the overall reduction is small.

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

MULLINS v. THE CONSOL ENERGY, INC. LONG TERM DISABILITY PLAN, No. 2:20-cv-01883 (W.D. Pa. Mar. 5, 2025)

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.

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