D. Massachusetts cuts commercial fee award over clerical work | LegalTime AI

D. Massachusetts cuts commercial fee award over clerical work

Nichole Sliney Realty Team, Inc. v. Mount Vernon Fire Insurance Company, No. 1:25-cv-11145. District Court, D. Massachusetts, Judge F. Dennis Saylor IV. Decided . Read the opinion

The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.

Commercial · Contract fee clause

What happened

The fee applicant sought fees under a contract fee clause for 207.4 hours. The court excluded tasks by Marissa K. Thomas that it found administrative, including sending certified mail, formatting responses, e-filing, filling out summons, and combining prior invoices. It also found that 108.3 of the 207.4 hours were block-billed, and applied a 15% global reduction to the attorney fee request. The court did not state dollar totals.

What the court said

Clerical work billed as legal work
some of the tasks conducted by Marissa K. Thomas—specifically, sending certified mail, formatting responses, e-filing, filling out summons, and combining prior invoices—should be excluded because they are administrative
Block billing · 15% reduction
of the 207.4 hours billed, 108.3 hours, or 52%, were block-billed. Therefore, a 15% global reduction in attorney's fees requests is reasonable and warranted.

Why it matters

The ruling shows courts will separate administrative tasks from legal work on a fee petition and will reduce the total fee when time entries combine multiple tasks. Block billing at the entry level can lead to a percentage cut across the whole request, not just the affected entries.

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

Nichole Sliney Realty Team, Inc. v. Mount Vernon Fire Insurance Company, No. 1:25-cv-11145 (D. Mass. Oct. 16, 2026)

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.

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