S.D. Florida cuts sanctions fee award 60%, including for block billing

What happened

The fee applicant sought $11,893 in sanctions fees. The court awarded $4,760, a reduction of $7,133 or 60%. It reduced the hourly rates for the two timekeepers, excluded time spent on tasks outside the four relevant areas, disallowed a block-billed entry that mixed attendance at a hearing with unrelated tasks, and allowed one hour of travel time given the distance between counsel's office and the courthouse.

What the court said

the only time entry that mentions attendance at the Hearing engages in the sin of block billing, meaning it includes several tasks, many of which are unrelated to attending the Hearing

The court also reduced the award for: hourly rate reduced, unrelated claims, travel time.

Why it matters

The ruling shows that a fee petition can be cut sharply when entries combine unrelated tasks and when billed rates exceed what the court accepts. Block billing left the court unable to separate compensable hearing attendance from other work, so the entry was excluded rather than trimmed.

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 S.D. Florida approves and attorney fee motions in Florida 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.