D. Arizona cuts wage and hour fee award 48.2%, including for clerical work

What happened

Frankel Syverson PLLC sought $22,270 in fees under the Fair Labor Standards Act for 68.8 hours. The court awarded $11,538.02, a reduction of $10,731.98 or 48.2%, and allowed 34.9 hours. It removed 8.4 hours for clerical and administrative tasks billed as legal work, then applied a 34% cut to compensable hours for entries it found unreasonable, after subtracting non-compensable fees motion time and clerical tasks.

What the court said

the Court will reduce the number of hours expended by an additional 8.4 hours to account for non-compensable clerical and administrative tasks.

The court also reduced the award for: excessive hours.

Why it matters

The ruling shows courts will separate administrative tasks from legal work and reduce hours for entries they find excessive, applying percentage cuts to the remaining compensable time rather than the full request.

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.

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