D. Arizona cuts wage and hour fee award 17.7%, including for clerical work

What happened

The plaintiff's counsel sought $7,342.50 in fees under the Fair Labor Standards Act for 16.5 hours of work. The court awarded $6,043.50, a reduction of $1,299.00 or 17.7%. It deducted 1.2 hours that it found were administrative entries billed as legal work, leaving 15.3 hours. It also reduced the hourly rate, citing prior awards to the same counsel in the District as consistent with prevailing community rates.

What the court said

Accordingly, a total of 1.2 hours for these administrative entries are appropriately deducted from the 16.5 hours billed by Plaintiff's counsel.

The court also reduced the award for: hourly rate reduced.

Why it matters

The ruling shows that courts will separate administrative tasks from legal work when reviewing time records, deducting those hours even in a small fee request. It also shows that a requested rate can be adjusted based on prior awards to the same lawyer in the same district.

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 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.