D. Arizona cuts civil rights fee award 24.5%, including for vague entries

What happened

Zwillinger Wulkan PLC, counsel for the fee applicant in a civil rights case, requested $983,227.16 in fees and costs under 42 U.S.C. Section 1988. Judge John C. Hinderaker awarded $742,161.66, a reduction of $241,065.50 or 24.5%. The court lowered an hourly rate, reduced travel time to half of standard rates, cut hours it found excessive across several periods, disallowed an entry not clearly related, and sustained objections to vague entries and administrative tasks billed as legal work.

What the court said

The Court sustains the vagueness objections to the entries on September 22, 25, 29, October 2, and November 22, 2023, which total .4 of an hour for Ms. Joachim’s time and .3 of an hour for Mr. Wulkan’s time.

The entries on 3/22/25 (.2) and 3/26/25 (1.0) are denied because they are administrative tasks.

The entry on 5/21/25 (2.1) is denied because it appears to have been needed due to the less-than-efficient method Mr. Moore used to maintain his time records, which required him to go back through his Outlook Calendar and recreate time entries

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

Why it matters

The ruling shows that a fee award can be reduced for several independent reasons, and that time records with vague descriptions, administrative tasks, or reconstructed entries draw specific cuts even when the larger reduction comes from hourly rates and excessive hours.

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.