D. Arizona cuts fee award 42.7%, including for vague entries

What happened

The fee applicant in Starboard Attitude Trust et al v. FirstFleet Incorporated sought $25,407.74 in sanctions, including costs. Judge Michael T. Liburdi awarded $14,560.40, a reduction of $10,847.34. The court cut 1.2 hours for preparing a notice of errata and reviewing the docket, and 1.2 hours for entries too vague to show what was done or whether the task was reasonable. It reduced by 20% entries that billed multiple tasks without separating the time, cut time on the motion to dismiss the amended complaint by 40% as excessive, and lowered the hourly rates for the shareholder counsel, senior associate counsel and associate counsel.

What the court said

The Court also declines to award fees for time spent in which the Court cannot determine what was done and whether the task was reasonable

The Court will also reduce by 20% entries that involved more than one task but did not indicate how long each task took

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

Why it matters

The ruling shows that a fee petition can lose value at several points: entries a court cannot parse, entries that bundle tasks, hours the court finds excessive, and rates above what the court allows. Each issue was addressed separately, so the final award reflects cumulative trimming rather than one across-the-board cut.

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 D. Arizona approves and attorney fee motions in Arizona 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.