N.D. Texas cuts commercial fee award 21.9%, including for vague entries

What happened

Salt and Light Energy Equipment LLC sought $1,356,037.25 in fees under a contract fee clause. Judge Godbey awarded $1,059,334.10, a reduction of $296,703.15 or 21.9%. The court lowered the hourly rates of Rodriguez, Delany, Ryder, Shook, Monette, and Smith to a baseline rate for lack of evidence of their experience, and reduced the law clerk rate as high compared to the prevailing market rate. It also applied a percentage reduction to exclude redacted entries, clerical work, and excessive or inadequately documented hours.

What the court said

to exclude charges for redacted billing entries in which the Court cannot determine whether the hours worked were reasonable, entries for clerical work, and entries with excessive (or inadequately documented) hours, the Court applies a twenty-five percent reduction

to exclude charges for redacted billing entries in which the Court cannot determine whether the hours worked were reasonable, entries for clerical work, and entries with excessive (or inadequately documented) hours, the Court applies a twenty-five percent reduction

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

Why it matters

The ruling shows that a fee applicant must document each timekeeper's experience to support rates above a baseline, and that redacted, clerical, and excessive entries can draw a single across-the-board percentage cut rather than an entry-by-entry review.

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

See hourly rates the N.D. Texas approves and attorney fee motions in Texas federal courts.

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