S.D. Florida cuts commercial fee award 9.4%, including for block billing

What happened

The fee applicant sought $21,376.75 under a contract fee clause, covering 82.39 hours. The court awarded $19,376.75, a reduction of $2,000. It applied a 15% reduction to the time one associate spent on the Complaint because the entries were block billed, and a further 15% reduction to that associate's time because a significant amount of time went to research and drafting a five-page Complaint.

What the court said

Therefore, based on a review of the billing entries, a 15% reduction of the time performed by Associates (at a rate of $250 per hour) for time spent on the Complaint is appropriate here.

The court also reduced the award for: excessive hours.

Why it matters

The ruling shows that block-billed entries can draw a percentage cut even when the overall reduction is modest, and that courts will trim time they see as disproportionate to the task, here research and drafting of a short complaint.

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 S.D. Florida approves and attorney fee motions in Florida 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.