D. Arizona cuts commercial fee award 55.7%, including for block billing

What happened

Strong & Hanni, PC, counsel for TAC Holdings LLC, sought $48,176.78 in sanctions fees, including costs, for 80.4 hours in a discovery dispute over the Bravada Defendants' missing bank statements. The court awarded $21,328, a reduction of $26,848.78 or 55.7%. It excluded five entries unrelated to that dispute and reduced $2,000 for block billing and heavily redacted entries, and $2,000 more because the post hoc reduction of time entries raised concerns about the record's accuracy and reliability.

What the court said

The time record reflects that the majority of the entries are either heavily redacted, billed in block format, or both.

Plaintiff's post hoc reduction of the time entries creates legitimate concerns about the time record's accuracy and reliability.

The court also reduced the award for: unrelated claims.

Why it matters

The ruling shows that courts will trim fee awards when time entries are block billed, heavily redacted, or reconstructed after the fact, and will exclude entries tied to claims outside the sanctioned dispute. It also shows that a fee applicant's own later reductions can undermine the reliability of the time record.

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 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.