N.D. California cuts commercial fee award 25% over missing contemporaneous records

What happened

Stellantis Financial Services sought $44,688.74 in fees under a contract fee clause, with Kutak Rock LLP as counsel. The court awarded $33,516.56, reducing the request by $11,172.18, or 25%. The court found that Stellantis had not provided detailed or itemized timekeeping records and concluded that a 25% reduction of the total fee was reasonable for that reason. The figures do not include costs.

What the court said

Because Stellantis has not provided detailed or itemized timekeeping records, the Court finds that it is reasonable to reduce the requested fee award by twenty-five percent.

Why it matters

The ruling shows that a court may apply a percentage cut to the entire fee request when the applicant does not supply detailed or itemized time records, even under a contract fee clause. It indicates that the absence of contemporaneous records can affect the award without a line-by-line review.

How to keep this out of your fee petition

• Record time the same day the work happens.
• Keep the original records, not only a cleaned-up summary.
• Be able to show when each entry was created.

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.