D. Arizona cuts civil rights fee award 6.1%, including for block billing

What happened

Prison Legal News, represented by Rosen Bien Galvan & Grunfeld LLP, sought $2,523,914 in fees and costs under 42 U.S.C. § 1988. The court awarded $2,370,881.67, including costs, a reduction of $153,032.33. It cut 10% from the challenged entries for block billing, 20% from the filing preparation entries for excessive hours, 70% from clerical hours, 70% from entries for unrelated claims, and denied a $20.88 expense.

What the court said

the Court will apply a 10% reduction to the $167,090.00 of billing entries Defendants challenge to account for impermissible block billing, yielding a reduction of $16,709.00.

the Court will reduce the purportedly clerical hours identified by Defendants by 70%, yielding a reduction of $20,843.20.

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

Why it matters

The ruling shows that block billing can draw a percentage cut even when the overall reduction is modest, and that courts separate recordkeeping problems from substantive ones like excessive hours or unrelated claims when calculating a fee award.

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. Arizona approves and attorney fee motions in Arizona 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.