D. Massachusetts cuts disability access fee award over vague entries

What happened

In Neal v. Omni Boston Corporation, an Americans with Disabilities Act case, the plaintiff sought attorney fees. The court did not state total amounts requested or awarded. It reduced the hours of one timekeeper by 80%, finding virtually all entries in that time sheet insufficiently detailed. The time sheet included over 20 entries described only as review email. The court applied the reduction to that timekeeper's hours.

What the court said

Virtually all entries in his time sheet are insufficiently detailed. His timesheet includes over 20 entries described only as “review email.”

Why it matters

The ruling shows that a time sheet with repeated generic descriptions can lose most of its value on a fee petition, even when the underlying work may have been done. Courts require entries specific enough to let the opposing party and the judge assess what was done and why.

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

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

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