S.D. California cuts consumer protection fee award 70%, including for clerical work

What happened

Knight Law Group, LLP sought $53,523.75 in fees and costs for the consumer protection action. The court awarded $16,029.45, a reduction of $37,494.30 or 70.0%. It lowered hourly rates, excluded hours of clerical work billed as legal work and hours of vague entries, and deducted time for duplicative staffing, excessive hours, and other items. It then reduced the lodestar by 10%, a $1,781.05 deduction, for staffing and billing inefficiencies.

What the court said

The Court excludes these billing entries from the fee award, which results in a deduction of 14 hours from Norman Little's time and 1.4 hours from Debra Reed's time.

The Court excludes these billing entries from the fee award, which results in a deduction of 2.5 hours from Norman Little's time, 0.3 hours from Russell Higgins's time, and 0.3 hours from Debra Reed's time.

the Court deducts 1.3 hours from Norman Little's time, 0.6 hours from Jacob Cutler's time, and 3.4 hours from Russell Higgins's time.

The Court excludes these billing entries from the fee award, which results in a deduction of 1.8 hours from Debra Reed's time and 1.2 hours from Norman Little's time.

The Court excludes these billing entries from the fee award, which results in a deduction of 4.1 hours from Norman Little's time.

Accordingly, the Court excludes the entry and deducts 1.0 hours from Debra Reed's time.

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

Why it matters

The ruling shows that courts will scrutinize time entries for clerical tasks and vague descriptions, and will exclude those hours rather than simply adjust the rate. It also shows that a percentage cut can follow itemized deductions when the court finds broader inefficiencies in staffing and billing.

How to keep this out of your fee petition

• Leave purely clerical work off the fee petition.
• Describe paralegal tasks so the substantive work is clear.
• Split mixed entries into their substantive and clerical parts.

Cite this ruling

See hourly rates the S.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.