E.D. California cuts commercial fee award 51.8%, including for vague entries

What happened

Manning Gross + Massenburg LLP sought $291,460 in fees under a contract fee clause for TBM N160TM, LLC and others. The court awarded $140,585, a reduction of $150,875 or 51.8%. It reduced the hourly rates because the requested rates exceeded those ordinarily awarded in the District. It deducted 16.2 hours from Sands' time for drafting the renewed motion between February 6 and February 12, 2026. It also cut the claimed hours by 25% as excessive for the scope and complexity of the litigation, and because the summary billing records did not let the court reliably separate complementary from duplicative work or assess vague entries.

What the court said

the summary billing records do not permit the Court to reliably distinguish complementary work from duplicative work

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

Why it matters

The ruling shows that a fee applicant's time records carry the burden of justifying hours. Summary billing that does not let the court separate complementary from duplicative work, or assess vague entries, can support a percentage cut even where the court also finds the hours excessive and the rates too high.

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 E.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.