D. Idaho cuts commercial fee award 55.4%, including for block billing

What happened

Precise Innovations, through Beard St. Clair Gaffney PA, sought $139,670.67 in fees under a contract fee clause. The court awarded $62,360.50, a reduction of $77,310.17 or 55.4%, with figures including costs. It declined fees for entries tied to filings that involved, at least in part, the tortious interference claim. It also declined fees for entries too general to exclude work on that claim and for block-billed entries.

What the court said

The Court also does not award fees for entries that are too general and could reasonably include work performed on the tortious interference claim or block-billed entries

The Court also does not award fees for entries that are too general and could reasonably include work performed on the tortious interference claim or block-billed entries

The court also reduced the award for: unrelated claims.

Why it matters

The ruling shows that a fee applicant must separate work on unsuccessful or non-compensable claims from compensable work. Entries too general to show what was done, and block-billed entries that combine tasks, can be excluded when the court cannot tell whether they include work on a claim it will not fund.

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 D. Idaho approves and attorney fee motions in Idaho 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.