S.D. Illinois cuts prisoner rights fee award 63.4%, including for vague entries | LegalTime AI

S.D. Illinois cuts prisoner rights fee award 63.4%, including for vague entries

Reed v. Larson, No. 3:18-cv-01182. District Court, S.D. Illinois, Judge J. Phil Gilbert. Decided . Read the opinion

Requested
$463,990.87
Awarded
$170,000
Cut
63.4%$293,990.87

Prisoner rights · 42 U.S.C. § 1988

What happened

The plaintiff sought $463,990.87 in attorney fees under 42 U.S.C. § 1988 for 820.2 hours. The court awarded $170,000, a reduction of $293,990.87 or 63.4%. It applied the PLRA hourly rate cap, excluded time on unrelated claims, and reduced total hours by 12% for excessive hours and by another 12% because the documentation for some time was vague and the entries were excessive or redundant. The figures do not include costs.

What the court said

Vague entries · 12% reduction
These times are excessive or redundant, and the documentation offered in support of them is vague.

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

Why it matters

The ruling shows that a fee award can be cut sharply even when the applicant prevails, and that time entries lacking detail may be reduced on their own, separate from other reductions for rate limits, unrelated claims, and excessive hours.

How to keep this out of your fee petition

  • Name the task, the document or person involved, and the purpose.
  • Avoid stock phrases that could describe any day in any matter.
  • Keep privileged detail general, but specific enough to show the work.

Cite this ruling

Reed v. Larson, No. 3:18-cv-01182 (S.D. Ill. Apr. 19, 2024)

See hourly rates the S.D. Illinois approves.

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.

More rulings like this

All rulings in the Fee Cut Tracker