M.D. Tennessee cuts fee award 82.5%, including for vague entries

What happened

The fee applicant sought $45,600 in sanctions under Rule 37, covering 96.6 hours and including costs. The court awarded $8,000, a reduction of $37,600 or 82.5%. It excluded time on unrelated claims, including 3.1 hours not tied to the motion to compel. It found the hours on the motion papers excessive and 2.5 hours by attorney Leniski duplicatively staffed. It declined to reallocate 6.0 paralegal hours with no description. It reduced the hourly rate and found 20 hours reasonable for discovery conferences and hearings.

What the court said

in the absence of any description of the 6.0 hours billed by paralegal Scott, the Court will not reallocate payment to Defendant.

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

Why it matters

The ruling shows that a fee petition must tie each time entry to the compensable motion and describe the work performed. Entries lacking description may be excluded, and courts will reduce hours found excessive or duplicative even when the overall request is supported by contemporaneous records.

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 M.D. Tennessee approves and attorney fee motions in Tennessee 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.