D. Hawaii cuts commercial fee award 47%, including for block billing | LegalTime AI

D. Hawaii cuts commercial fee award 47%, including for block billing

Privratsky v. Liberty Mutual Fire Insurance Company, No. 1:21-cv-00390. District Court, D. Hawaii, Judge Derrick K. Watson. Decided . Read the opinion

Requested
$693,652.50
Awarded
$367,524.91
Cut
47%$326,127.59

Commercial · Fee applicant's counsel: Goodsill Anderson Quinn & Stifel

What happened

Liberty Mutual, through Goodsill Anderson Quinn & Stifel, sought $693,652.50 in fees. The magistrate judge recommended reducing the requested hours by 10% for excessive and duplicative billing, 20% for block billing, 5% for insufficient descriptions and 5% for clerical tasks. The court also excluded 8 hours, or $1,427.50, for unrelated claims. Judge Derrick K. Watson awarded $367,524.91, a reduction of $326,127.59, or 47.0%.

What the court said

Block billing · 20% reduction
the Magistrate Judge reduced Liberty’s requested hours for “excessive and duplicative billings”, “block-billed” entries, “insufficient descriptions”, and “clerical tasks” by, ten, twenty, five, and five
Vague entries · 5% reduction
the Magistrate Judge reduced Liberty’s requested hours for “excessive and duplicative billings”, “block-billed” entries, “insufficient descriptions”, and “clerical tasks” by, ten, twenty, five, and five
Clerical work billed as legal work · 5% reduction
the Magistrate Judge reduced Liberty’s requested hours for “excessive and duplicative billings”, “block-billed” entries, “insufficient descriptions”, and “clerical tasks” by, ten, twenty, five, and five

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

Why it matters

The ruling shows that percentage cuts can be applied cumulatively to a fee request, with block billing drawing the largest single reduction. It also shows courts separating time on unrelated claims from the overall percentage reductions, so the final award reflects both across-the-board and claim-specific trimming.

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

Privratsky v. Liberty Mutual Fire Insurance Company, No. 1:21-cv-00390 (D. Haw. Aug. 11, 2026)

See hourly rates the D. Hawaii approves and attorney fee motions in Hawaii 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.

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