Bankr. N.D. Illinois cuts bankruptcy fee award 65%, including for clerical work

What happened

The fee applicant sought $5,925 under a contract fee clause. Judge Michael B. Slade awarded $2,075, a reduction of $3,850 or 65%. The court allowed set per-notice amounts for required payment change notices and for necessary notices of fees, with several of each filed to date. It found that completing, serving, and filing two two-page forms was clerical work, and that the per-notice charges were not reasonable absent contrary evidence.

What the court said

And the completion, service, and filing of two two-page forms is plainly clerical work.

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

Why it matters

The ruling shows that bankruptcy courts will separate clerical tasks from legal work and will test per-notice charges against evidence of reasonableness, so time and task records must support each billed item rather than treat routine form filings as legal services.

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

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.