S.D. Florida cuts commercial fee award 48.1%, including for clerical work

What happened

PNC Bank sought $8,951 in attorney fees under a contract fee clause, billing 34.8 hours. The court awarded $4,644, a reduction of $4,307 or 48.1%. It deducted 0.8 hours of paralegal time for clerical tasks, 0.4 hours for vague entries, 0.5 hours from one attorney, 9.8 hours for work on a renewed default judgment motion, and 4.0 hours for litigating the fee amount. It also reduced the hourly rate.

What the court said

Both of these tasks are clerical in nature, and thus the Court recommends deducting .8 hours from Paralegal Lockley's total hours.

the Court recommends deducting .4 hours from Paralegal Lockley's total hours to account for these vague entries.

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

Why it matters

The ruling shows that courts separate clerical tasks and vague time entries from compensable legal work, and that fee petitions can lose hours for work the court attributes to the applicant's own mistakes or to fee litigation itself.

How to keep this out of your fee petition

• Leave purely clerical work off the fee petition.
• Describe paralegal tasks so the substantive work is clear.
• Split mixed entries into their substantive and clerical parts.

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.