N.D. Texas cuts commercial fee award 2.1% over vague entries

What happened

The fee applicant sought $104,429.50 under a contract fee clause. The court awarded $102,201, a reduction of $2,228.50, or 2.1%. It disallowed $367.50 for 0.7 hours because redactions made a February 8, 2023 entry unintelligible. It disallowed $1,581 for 3.4 hours of clerical tasks billed as legal work. It disallowed $280 for 1.0 hour that was block-billed with clerical tasks, and another $280 for 1.0 hour of block-billed clerical work, because the court could not identify the reasonable rate for each service.

What the court said

Bullock's February 8, 2023 entry is unrecoverable because these redactions "effectively render the billing entries unintelligible."

Defendants failed to demonstrate that such fees for purely clerical tasks are either reasonable or necessary, making them unrecoverable.

Her March 7 and 22 entries are block-billed with purely clerical tasks, e.g., calendaring deadlines, meaning this Court cannot adequately identify the reasonable rate for each particular service performed.

Her March 7 and 22 entries are block-billed with purely clerical tasks, e.g., calendaring deadlines, meaning this Court cannot adequately identify the reasonable rate for each particular service performed.

Why it matters

The ruling shows that courts will examine individual time entries and reduce fees when redactions leave entries unreadable, when clerical tasks are billed as legal work, or when block billing prevents the court from separating compensable from noncompensable time.

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 N.D. Texas approves and attorney fee motions in Texas federal courts.

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