S.D. Florida cuts commercial fee award 16.4%, including for vague entries

What happened

PNC Bank sought $5,471 in fees under a contract fee clause, based on 20.1 hours. The court awarded $4,576.75, a reduction of $894.25 or 16.4%. It found the hourly rates for Ms. Owens and Ms. Bowers unreasonably high. It also identified entries for email communications with redactions that made them vague and appeared duplicative, entries that appeared duplicative and unnecessary, and time entries related to Ms. Vinci's case that should not be recoverable. The court reduced recoverable fees from attorney work by 15%.

What the court said

First, there are entries regarding email communications with redactions that make the entries vague and appear duplicative.

The court also reduced the award for: hourly rate reduced, duplicative staffing, unrelated claims, other.

Why it matters

The ruling shows that courts examine the text of time entries for clarity and duplication, and that redactions can make otherwise billable email entries vague. It also confirms that a fee applicant must separate time spent on unrelated matters and that a percentage cut may be applied to a subset of entries rather than the whole request.

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 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.