N.D. Texas cuts sanctions fee award, including for block billing

What happened

The fee applicant sought sanctions fees. The court denied $6,014 for 17.5 hours of fees on fees, $1,622.50 for 4.8 hours of post-filing work, $11,762 for 34.9 hours of post-filing fees, and $19 for 0.1 hours on an unrelated matter. It then reduced by half the $4,213.50 requested for 12 hours of pre-filing work because those entries mixed matters within and outside the order's scope.

What the court said

Here, entries that contain matters both within and outside the order's scope will be uniformly reduced by half their respective hours. So the Court reduces – by one half – the requested $4,213.50 for 12 hours of pre-filing work.

The court also reduced the award for: fees on fees, other, fees on fees, unrelated claims.

Why it matters

The ruling shows that courts will separate fee requests by task and deny categories not reasonably incurred, and that entries combining covered and uncovered work may be cut by a set fraction rather than parsed line by line.

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 N.D. Texas approves and attorney fee motions in Texas 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.