E.D. New York cuts wage and hour fee award 47.7%, including for vague entries

What happened

The plaintiff sought $5,848 in attorney fees under the Fair Labor Standards Act for 13.4 hours. The court reduced the requested hourly rates for the attorneys. It also reduced fees for vague time entries, noting that three of four entries by one attorney stated only correspondence review, which the court found too vague to assess. The court awarded $3,057.50, a reduction of $2,790.50 or 47.7%.

What the court said

three of Mr. Samuel’s four time entries state the same action: “correspondence review.” This description is too vague for the Court to determine its reasonableness

The court also reduced the award for: hourly rate reduced, hourly rate reduced.

Why it matters

The ruling shows that courts will cut fees when time entries do not describe the work with enough specificity to assess reasonableness, and that rate reductions can compound those cuts. It also confirms that even small fee requests are subject to entry-by-entry review.

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 E.D. New York approves and attorney fee motions in New York 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.