D. Oregon cuts commercial fee award 6.4%, including for block billing

What happened

Nufarm Americas sought $27,122.75 in attorney fees under a contract fee clause. The court awarded $25,384.50, a reduction of $1,738.25, or 6.4%. It cut two block-billed entries exceeding three hours by 50% each, reducing the award by $1,020.25. It excluded $315 for purely clerical tasks billed as legal work and $403 for entries whose compensability was unclear. The court awarded fees for 78.8 hours.

What the court said

Mr. Ripp submits two block-billed time entries exceeding three hours, one for November 29, 2022, and the other for December 2, 2022. The Court reduces each of these two entries by 50 percent, thereby reducing Plaintiff's fee award by $1,020.25.

The Court reduces Plaintiff's award by $315, the amount related to the above-identified purely clerical tasks.

The court also reduced the award for: other.

Why it matters

The ruling shows that courts will reduce fee awards when time entries combine multiple tasks into a single block, making it hard to assess reasonableness. It also confirms that clerical tasks are not compensable as attorney time and that unclear entries may be excluded entirely.

How to keep this out of your fee petition

• Record one task per entry, each with its own time.
• Write the entry when the work happens, not at the end of the week.
• If a task really is one unit of work, say what it was and what it produced.

Cite this ruling

See hourly rates the D. Oregon approves and attorney fee motions in Oregon 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.