D. Idaho cuts commercial fee award 10.7%, including for clerical work

What happened

Dunn & Black, P.S., counsel for the fee applicant, requested $15,695.50 for 44.1 hours. The court awarded $14,024.50 for 37.5 hours, a reduction of $1,671. It cut 5.4 hours at the associate rate, a $1,431 reduction, finding 18 hours reasonable for that work. It also deducted 1.2 hours at the staff rate, $240, because clerical tasks are not compensable.

What the court said

Because such tasks are not compensable, the Court deducts 1.2 hours at the staff rate of $200 per hour, for a reduction of $240.

The court also reduced the award for: excessive hours.

Why it matters

The ruling shows courts will trim fee requests for time that is excessive and for clerical tasks billed at professional rates. It also shows that a single entry category can be reduced on more than one ground, with each deduction tied to a specific rate and hour count.

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. Idaho approves and attorney fee motions in Idaho 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.