Missing contemporaneous time records: how courts cut fee awards
Many courts require fee applicants to submit time records made at or near the time the work was done. Without them, courts reduce the award, and some courts deny fees for the undocumented time altogether.
- Rulings tracked
- 47
- Median cut for this reason
- 25%
- Total fees cut in these rulings
- $2.6M
Median of the percentage reductions courts stated for no contemporaneous records. Totals cover every reduction in those rulings.
What courts say
The Court finds that it is reasonable to reduce the requested fee award by twenty-five percent given the non-contemporaneous nature of Mr. Riley’s billing records.
we fail to see why it is reasonable for defendants to pay for counsel’s failure to keep detailed contemporaneous records
the Court finds that a reduction of 40% of the total hours claimed by Troy Law is appropriate, if not conservative
While the declaration describes these amounts as “comparable” to the amount that would be earned by working a certain number of hours, there is not an actual accounting of hours worked.
the fees requested for Jones are GRANTED, and the fees requested for Trout, Schossberger, Kluckhohn, and Zywicki must be DENIED.
How to keep it out of your fee petition
- Record time the same day the work happens.
- Keep the original records, not only a cleaned-up summary.
- Be able to show when each entry was created.
More: what a fee declaration needs · fee cuts for bad time records
FAQ
What is no contemporaneous records in legal billing?
Many courts require fee applicants to submit time records made at or near the time the work was done. Without them, courts reduce the award, and some courts deny fees for the undocumented time altogether.
How much do courts cut attorney fees for no contemporaneous records?
When federal courts cut fees for missing contemporaneous records, the median reduction they applied was 25% (24 rulings since January 2024).
How often do courts cut fees for no contemporaneous records?
In 2.9% of federal fee rulings that cut a fee since January 2024 (60 rulings).
How do you avoid no contemporaneous records on a fee petition?
Record time the same day the work happens. Keep the original records, not only a cleaned-up summary. Be able to show when each entry was created.
Rulings that cut fees for no contemporaneous records
| Date | Court | Case | Practice area | Requested | Awarded | Cut | Recordkeeping reasons |
|---|---|---|---|---|---|---|---|
| Oct 15, 2026 | N.D. California | Innovative Sports Management, Inc. v. Lizcano et al | $16,562.50 | $11,593.75 | 30% | Missing contemporaneous records | |
| Sep 24, 2026 | E.D. Pennsylvania | HICKS v. CITY OF PHILADELPHIA et al | Civil rights | $290,890 | $132,354.95 | 54.5% | Clerical work billed as legal work, Block billing, Missing contemporaneous records |
| Sep 8, 2026 | E.D. New York | Han v. Shang Noodle House, Inc. et al | Wage and hour | $71,763 | $25,732.41 | 64.1% | Clerical work billed as legal work, Clerical work billed as legal work, Vague entries, Missing contemporaneous records |
| Aug 13, 2026 | M.D. Tennessee | Beekeepers Mill LLC v. Welcome Mat Vacations LLC et al | Consumer protection | Not stated | Not stated | See ruling | Missing contemporaneous records, Reconstructed time |
| Jun 22, 2026 | D. Idaho | Yates v. Insure Right Insurance Agency, LLC | Employment | $37,325.50 | $13,282.50 | 64.4% | Missing contemporaneous records |
| Jun 17, 2026 | E.D. New York | St. Marys Cement U.S. LLC v. Red Rock Industries, Inc. et al | Commercial | $61,087.04 | $30,000 | 50.9% | Missing contemporaneous records, Vague entries |
| Jun 8, 2026 | N.D. California | Innovative Sports Management Inc v. Sanchez et al | $12,062.50 | $7,840.63 | 35% | Missing contemporaneous records | |
| Jun 2, 2026 | M.D. Pennsylvania | Siras v. Bah et al | Not stated | Not stated | See ruling | Block billing, Clerical work billed as legal work, Missing contemporaneous records | |
| Jun 2, 2026 | E.D. New York | PHH Mortgage Corporation v. Allwood et al | Commercial | $6,800 | $3,400 | 50% | Missing contemporaneous records |
| May 4, 2026 | N.D. California | Stellantis Financial Services, Inc. v. Winding | Commercial | $44,688.74 | $33,516.56 | 25% | Missing contemporaneous records |
| Apr 1, 2026 | Bankr. S.D. Texas | Landry, Jr v. Scroggins et al | Bankruptcy | $24,000 | $15,600 | 35% | Missing contemporaneous records |
| Feb 17, 2026 | D. Kansas | Stuart et al v. Topeka, Kansas, City of et al | Employment | $915,162.50 | $279,852.50 | 69.4% | Block billing, Missing contemporaneous records, Clerical work billed as legal work |
| Feb 12, 2026 | E.D. New York | Deutsche Bank National Trust Company v. Tacoaman et al | Commercial | $6,800 | $3,400 | 50% | Missing contemporaneous records |
| Dec 12, 2025 | N.D. Texas | JTH Tax LLC v. Brown et al | Intellectual property | $93,446.58 | $53,545.75 | 42.7% | Missing contemporaneous records |
| Nov 25, 2025 | Bankr. S.D. Ohio | Arlene Huff | Bankruptcy | Not stated | Not stated | See ruling | Missing contemporaneous records |
| Oct 28, 2025 | E.D. New York | JTH Tax LLC v. Kukla et al | Commercial | Not stated | Not stated | 15% for records | Missing contemporaneous records |
| Oct 7, 2025 | N.D. California | Innovative Sports Management, Inc. v. Lizcano Reyes | $5,837.50 | $3,283.59 | 43.8% | Missing contemporaneous records | |
| Aug 27, 2025 | N.D. California | Moralez v. Monterey Plaza Hotel Limited Partnership, et al | Disability access | $1,249,454 | $234,958.27 | 81.2% | Missing contemporaneous records |
| Jun 25, 2025 | E.D. Michigan | Brown et al v. MGM Grand Casino | Employment | $434,130 | $393,680 | 9.3% | Missing contemporaneous records |
| Jun 6, 2025 | E.D. Pennsylvania | Moorehead v. SCHOOL DISTRICT OF THE CITY OF ALLENTOWN et al | Civil rights | Not stated | Not stated | 20% for records | Clerical work billed as legal work, Clerical work billed as legal work, Block billing, Vague entries, Missing contemporaneous records, Vague entries, Clerical work billed as legal work, Vague entries, Missing contemporaneous records, Clerical work billed as legal work |
| May 27, 2025 | N.D. California | Quicklogic Corporation v. Konda Technologies, Inc. et al | Intellectual property | Not stated | Not stated | See ruling | Missing contemporaneous records |
| May 15, 2025 | E.D. California | G & G Closed Circuit Events, LLC v. Barksdale et al | $19,107.50 | $8,250 | 56.8% | Missing contemporaneous records, Block billing, Clerical work billed as legal work, Clerical work billed as legal work | |
| May 9, 2025 | D. Puerto Rico | Betancourt Colon v. Arcos Dorados Puerto Rico, LLC. | Disability access | Not stated | Not stated | See ruling | Missing contemporaneous records |
| Apr 28, 2025 | S.D. California | Case Name in Social Security Case - Unavailable | Social Security | $47,728.44 | $12,179.44 | 74.5% | Clerical work billed as legal work, Vague entries, Block billing, Block billing, Clerical work billed as legal work, Missing contemporaneous records |
| Feb 18, 2025 | E.D. Pennsylvania | HOVAGIMIAN et al v. HOME EXCHANGE NJ LLC et al | Commercial | Not stated | Not stated | See ruling | Missing contemporaneous records |
| Jan 10, 2025 | N.D. New York | U.S. Bank National Association v. Chenango Place, LLC et al | Commercial | $88,493.30 | $82,479.60 | 6.8% | Missing contemporaneous records |
| Dec 20, 2024 | E.D. California | (PC) Doe et al v. State of California et al | Civil rights | $40,768.15 | $35,246.25 | 13.5% | Clerical work billed as legal work, Missing contemporaneous records |
| Dec 12, 2024 | W.D. New York | Pickering v. U.S. Department of Justice et al | FOIA | $4,439.60 | $1,666.67 | 62.5% | Missing contemporaneous records |
| Nov 26, 2024 | D. Idaho | Gerard and Heather Ann Hart Living Trust, et al. v. Legends Development Company, et al. | Commercial | $91,315.50 | $88,300.50 | 3.3% | Missing contemporaneous records |
| Nov 14, 2024 | W.D. New York | Pickering v. U.S. Department of Justice et al | FOIA | $4,439.60 | $1,666.67 | 62.5% | Missing contemporaneous records |
| Oct 17, 2024 | E.D. California | Hernandez v. Welcome Sacramento LLC et al | Disability access | $53,236.27 | $49,029 | 7.9% | Clerical work billed as legal work, Missing contemporaneous records, Clerical work billed as legal work |
| Oct 10, 2024 | E.D. Michigan | G&G Closed-Circuit Events, LLC v. Brothers Bar & Grill, LLC et al | $8,729.30 | $3,839.50 | 56% | Missing contemporaneous records, Vague entries | |
| Aug 26, 2024 | N.D. Texas | Waller v. The Salvation Army | Employment | $155,200 | $99,456 | 35.9% | Vague entries, Vague entries, Missing contemporaneous records, Block billing |
| Aug 19, 2024 | E.D. New York | Alzal Corp. v. Killer Carz, LLC et al | Commercial | $111,428.20 | $77,984.50 | 30% | Missing contemporaneous records, Missing contemporaneous records, Missing contemporaneous records, Missing contemporaneous records |
| Aug 6, 2024 | D. Utah | Lynch v. Leatherheads Sports Grill | Intellectual property | $23,410 | $7,500 | 68% | Missing contemporaneous records |
| Jul 9, 2024 | E.D. New York | A.H., an infant under the age of 18 years by his Mother and Natural Guardian, JOAN ASLARONA v. The Board of Education of The City of New York et al | Civil rights | Not stated | Not stated | 30% for records | Missing contemporaneous records |
| May 28, 2024 | D. Massachusetts | Christopher Drennen v. Fresenius Medical Care Holdings, Inc., | Not stated | Not stated | 10% for records | Block billing, Vague entries, Missing contemporaneous records, Clerical work billed as legal work | |
| Apr 30, 2024 | E.D. California | Early et al v. Keystone Restaurant Group, LLC et al | Employment | $630,387 | $346,192.50 | 45.1% | Vague entries, Missing contemporaneous records, Reconstructed time |
| Apr 15, 2024 | N.D. California | Silicon Genesis Corporation v. EV Group E.Thallner GmbH | Commercial | Not stated | Not stated | 25% for records | Missing contemporaneous records, Vague entries |
| Mar 18, 2024 | S.D. California | G & G Closed Circuit Events, LLC v. Finch et al | $3,946.30 | $1,050 | 73.4% | Missing contemporaneous records, Clerical work billed as legal work | |
| Mar 8, 2024 | E.D. New York | Freedom Mortgage Corporation v. Rich et al | Commercial | $5,650 | $3,650 | 35.4% | Missing contemporaneous records |
| Mar 8, 2024 | Bankr. E.D. California | Buettner, III et al v. Residential Funding Corporation et al | Bankruptcy | $59,475 | $47,580 | 20% | Missing contemporaneous records, Reconstructed time |
| Feb 20, 2024 | E.D. New York | Henni v. Rotana Cafe & Restaurant Inc. et al | Wage and hour | $5,250 | $2,000 | 61.9% | Missing contemporaneous records, Reconstructed time |
| Feb 16, 2024 | E.D. New York | Jane Doe v. Golden Krust Caribbean Bakery & Grill Inc. et al | Employment | $32,670 | $13,824 | 57.7% | Missing contemporaneous records, Clerical work billed as legal work |
| Jan 18, 2024 | N.D. Texas | Gilman v. Shellpoint Mortgage Servicing | Commercial | $39,946.50 | $31,946.50 | 20% | Missing contemporaneous records |
| Jan 17, 2024 | W.D. Missouri | Carson v. Citadel Federal Solutions, LLC | Consumer protection | $43,285 | $24,480 | 43.4% | Missing contemporaneous records |
| Jan 3, 2024 | W.D. Pennsylvania | DAVISON DESIGN & DEVELOPMENT, INC. v. SCORZA | Commercial | $49,619.73 | $17,837.83 | 64.1% | Missing contemporaneous records |
Spot an error? Email team@legaltime.ai with the case name and we will correct it. Summaries of public court opinions. Not legal advice.