D. Puerto Rico cuts fee award 36.5%, including for block billing

What happened

The fee applicant, Shullman Fugate PLLC, sought $62,020.70 for 149.9 hours. The court awarded $39,413.25, a reduction of $22,607.45 or 36.5%. It reduced a subset of entries by 30% for excessive hours, block billing, and vague entries; reduced a subset by 50% for secretarial tasks billed at legal rates; reduced two entries by 25% after the applicant acknowledged overstating them; and declined to apply South Florida rates wholesale.

What the court said

the Court concludes that some of the hours for which Defendants seek fees are excessive, involve block-billing, or are too generic or vague for the Court to assess whether the time billed was appropriate. The Court will reduce the following entries by 30 percent.

the Court concludes that some of the hours for which Defendants seek fees are excessive, involve block-billing, or are too generic or vague for the Court to assess whether the time billed was appropriate. The Court will reduce the following entries by 30 percent.

the Court concludes that some of the hours for which Defendants seek fees involve secretarial tasks that ought to be reimbursed at a lower rate, comparable to what paralegals are afforded in this District. The Court will reduce the following entries by 50 percent.

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

Why it matters

The ruling shows that a fee award can be cut on several fronts at once: entries that combine tasks or lack detail, clerical work billed at legal rates, and hours the court finds excessive. It also shows courts may adjust the hourly rate rather than accept the applicant's requested forum rates.

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 D. Puerto Rico 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.