S.D. California cuts fee award 54.8%, including for block billing | LegalTime AI

S.D. California cuts fee award 54.8%, including for block billing

Pioneers Memorial Healthcare District v. Imperial Valley Healthcare District et al, No. 3:24-cv-00861. District Court, S.D. California, Judge Hon. Janis L. Sammartino. Decided . Read the opinion

Requested
$156,522
Awarded
$70,754.80
Cut
54.8%$85,767.20

What happened

The fee applicant sought $156,522 in fees for 287.6 hours. The court awarded $70,754.80, a reduction of $85,767.20 or 54.8%. It excluded 18.9 hours on unrelated claims and 111.28 hours spent on a preliminary injunction motion, and found 16.5 hours excessive and duplicative. It also reduced by 20% the fees for preparing the fee statement, to account for hours billed in block format.

What the court said

Block billing · 20% reduction
the Court finds a reduction by 20 percent for the fees associated with preparing PMHD's fee statement to fairly balance the hours that were actually billed in block format.

The court also reduced the award for: unrelated claims, excessive hours, duplicative staffing, unrelated claims.

Why it matters

The ruling shows that a fee petition can lose more than half its value through both claim-level exclusions and recordkeeping problems. Courts will separate time on unsuccessful or unrelated claims and will apply a percentage cut where block billing prevents line-by-line review, even to the fee statement itself.

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

Pioneers Memorial Healthcare District v. Imperial Valley Healthcare District, No. 3:24-cv-00861 (S.D. Cal. Apr. 11, 2025)

See hourly rates the S.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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