M.D. Pennsylvania cuts fee award, including for block billing

What happened

Gardner Law Office sought fees in this case. The court reduced Attorney Gardner's hourly rate, applied the bottom of the range for reasonable Williamsport rates, and lowered the paralegal rate. It found the billing to be a form of block billing, cut mixed entries by 50%, disallowed time spent informing French counsel of American counsel's work as duplicative, excised travel time, declined fees on fees, and awarded only 39.8 hours, excluding 1.5 hours submitted without a supplemental log.

What the court said

This is an egregious form of block billing. Petitioner has not provided any indication of the total amount of hours worked, nor what those hours were incurred for.

The Court will reduce any such instances to the rate determined appropriate for the paralegal in this case, $75 per hour.

However, the Court will only award the hours submitted in a billing log with sufficient detail as to justify an award; the additional 1.5 hours which has appeared in Petitioner’s second submission without a supplemental hours log will not be awarded.

The court also reduced the award for: hourly rate reduced, hourly rate reduced, hourly rate reduced, duplicative staffing, other, unrelated claims, fees on fees, travel time.

Why it matters

The ruling shows that a fee petition can lose value at several points: rates, block-billed entries, duplicative staffing, travel, and hours submitted without a contemporaneous log. Courts will award only hours documented with enough detail to justify them, even when the applicant otherwise prevails.

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 M.D. Pennsylvania approves and attorney fee motions in Pennsylvania federal courts.

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