E.D. California cuts disability access fee award, including for vague entries

What happened

Moore Law Firm, P.C. sought fees under the Americans with Disabilities Act in Sellers v. Kaur. The court did not state totals. It cut 1.0 attorney hour ($300) as excessive and 1.0 hour ($300) for vague entries, noting over 2 hours described only attention to preparation of the amended complaint. It reduced discovery time by 6 attorney hours ($1,800) and 2 paralegal hours ($230), and found some descriptions vague or block billed. It cut 3.5 hours ($1,050) as excessive and reduced fees-on-fees hours by 10 ($1,150) and 0.5 ($150).

What the court said

there is some vagueness in the description of tasks, as over 2 hours of attorney time includes the description of "attention to preparation" of the FAC, which does not describe a specific task.

Some of the billing descriptions are also vague, or could be considered block billing, such as two hours for continued preparation of discovery requests on 1/30/24 and 4.5 hours "preparation for deposition" on 3/26/24.

Some of the billing descriptions are also vague, or could be considered block billing, such as two hours for continued preparation of discovery requests on 1/30/24 and 4.5 hours "preparation for deposition" on 3/26/24.

The court also reduced the award for: excessive hours, excessive hours, excessive hours, excessive hours, fees on fees, fees on fees.

Why it matters

The ruling shows that courts will trim fee requests when time entries describe attention to a task without identifying it, and when entries combine multiple tasks or lack specificity. It also confirms that excessive hours and fees-on-fees work draw separate reductions, so precise, task-specific records matter.

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 E.D. California approves and attorney fee motions in California 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.