Bankr. S.D. Ohio cuts bankruptcy fee award 1.4%, including for vague entries

What happened

Tax Workout Group, counsel for Timothy and April Naff, requested $4,345.50 in fees. The court awarded $4,287, a reduction of $58.5 or 1.4%. The court reduced two 0.1-hour entries by $2.00 each. It also reduced a 0.1-hour entry by $54.5 because the entry did not explain what legal service Mr. Kamensky provided, because it was his only entry in the case, and because the hourly rate charged was far above the range for experienced consumer bankruptcy practitioners in the Dayton, Ohio area.

What the court said

First, it does not explain what legal service Mr. Kamensky provided.

The court also reduced the award for: hourly rate reduced, hourly rate reduced, other, hourly rate reduced.

Why it matters

The ruling shows that courts examine individual time entries for specificity and may reduce fees when an entry does not describe the service performed. It also shows that a single isolated entry by a professional can draw scrutiny, and that requested hourly rates are compared against local market rates for similar practitioners.

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 Bankr. S.D. Ohio approves.

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.