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

What happened

The fee applicant sought $45,600 in sanctions, including costs, for 96.6 hours. The court awarded $8,000, a reduction of $37,600 or 82.5%. It excluded time on unrelated claims, found the time spent on the motion papers excessive, and cut 2.5 duplicative hours for a discovery hearing. It also declined to award 6.0 paralegal hours that had no description, reduced the hourly rate, and found 20 hours reasonable for the 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 can lose substantial time when entries lack descriptions, when work spans claims outside the fee basis, and when staffing or hours appear excessive. Courts will reduce or decline hours they cannot verify from the records, even in a sanctions context.

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.