N.D. California cuts ERISA benefits fee award 5.4% over clerical work | LegalTime AI

N.D. California cuts ERISA benefits fee award 5.4% over clerical work

Operating Engineers Health And Welfare Trust Fund et al v. Eagle Environmental & Construction et al, No. 3:25-cv-02524. District Court, N.D. California, Judge Kandis A. Westmore. Decided . Read the opinion

Requested
$3,020.50
Awarded
$2,856.50
Cut
5.4%$164

ERISA benefits · ERISA

What happened

The plaintiffs in an ERISA benefits case requested $3,020.50 in attorney fees. Judge Kandis A. Westmore awarded $2,856.50, a reduction of $164, after excluding 0.8 hours that the court found were clerical tasks, including calendaring, e-filing, and mailing documents, billed as legal work. The court said such clerical tasks are not compensable. The figures do not include costs.

What the court said

Clerical work billed as legal work · $164
Plaintiffs also include clerical work by Ms. Woods, such as calendaring, e-filing, and mailing documents. Such clerical tasks are not compensable.

Why it matters

The ruling shows that courts will separate clerical tasks from legal work on a fee petition and will reduce the award for time spent on tasks the court treats as noncompensable, even when the reduction is small.

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

Operating Engineers Health And Welfare Trust Fund v. Eagle Environmental & Construction, No. 3:25-cv-02524 (N.D. Cal. Oct. 16, 2025)

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