D. Minnesota cuts consumer protection fee award 2.2%, including for clerical work

What happened

The fee applicant in Singh v. Experian Information Solutions asked for $20,622.50 in fees, covering 47.4 hours. The court awarded $20,175, a reduction of $447.50 or 2.2%. It deducted 1.5 hours for seven entries it found entirely administrative, 0.5 hours at an attorney rate and 1.0 hour at a paralegal rate, and deducted 0.2 hours for another reason. The court also declined at that time to award fees for 7.9 hours spent preparing the reply.

What the court said

The Court identifies seven entries that appear to be entirely administrative, totaling 0.5 hours at an attorney rate and 1.0 hours at a paralegal rate. Those amounts are deducted from the fee award.

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

Why it matters

The ruling shows that courts review individual time entries and separate administrative tasks from legal work, deducting hours billed at attorney and paralegal rates accordingly. It also shows that a court may defer, rather than deny, fees for reply briefing while resolving the rest of the fee 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. Minnesota approves and attorney fee motions in Minnesota 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.