D. Minnesota cuts special education fee award 14.9%, including for block billing

What happened

The School Law Center, LLC sought $205,298.75 in fees under the IDEA. The court awarded $174,617.56, a reduction of $30,681.19. It deleted $250 for unrelated claims, cut a subset of entries by 30% for block billing, deducted $750 for 7.5 hours of law clerk time billed as legal work, halved two block-billed entries for $387.50 and $450, and applied a 15% deduction to the final award for block billing, vague entries, and billing in 15-minute increments.

What the court said

The Court finds that a 30% reduction to these fees is appropriate, rather than a reduction in specific hours because such a reduction would be difficult to calculate.

7.50 hours of improperly-billed law clerk time (01/27/21; 01/31/21), or $750.00, is easily deducted from the above billing statement.

Accordingly, the fee is further reduced by $387.50 (3.875 hrs. x $100.00).

the Court will reduce the fees by half for the Goetz 01/25/21 block-billed entry that contains two different tasks for an additional reduction of $450.00 (1.125 hrs. x $400.00).

the Court will apply a 15% deduction to the final fees award to account for block billing, vague billing entries, and for billing in 15-minute increments.

the Court will apply a 15% deduction to the final fees award to account for block billing, vague billing entries, and for billing in 15-minute increments.

The court also reduced the award for: unrelated claims, other.

Why it matters

The ruling shows courts will reduce fees for time records that combine tasks, describe work vaguely, or bill clerical time at legal rates, and may apply a percentage cut to the whole award when entry-by-entry review is impractical.

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. Minnesota approves and attorney fee motions in Minnesota 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.