N.D. California cuts fee award 36%, including for block billing

What happened

The fee applicant sought $311,714.50 in sanctions fees. The court denied $48,638.50 for deposition-related hours and excluded those hours from its reasonableness analysis. It then applied a 25% reduction to each block-billed entry, a 10% reduction to vague entries, and three additional 5% reductions to the total fee for duplicative staffing, unrelated claims, and excessive hours. The court awarded $199,644.82, a reduction of $112,069.68, or 36.0%.

What the court said

the Court finds it appropriate to apply a downward adjustment of 25% to each block-billed entry.

the Court will deduct 10% from the following vague entries

The court also reduced the award for: other, duplicative staffing, unrelated claims, excessive hours.

Why it matters

The ruling shows that courts will reduce fee awards when time entries combine tasks or lack detail, and that recordkeeping problems can compound with other reductions. It also shows that block billing and vague entries are treated as separate grounds for cuts, each applied to the affected entries rather than the whole fee.

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 N.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.