District of Columbia cuts ERISA benefits fee award, including for clerical work
TRUSTEES OF THE IAM NATIONAL PENSION FUND v. M & K EMPLOYEE SOLUTIONS, LLC et al, No. 1:20-cv-00433. District Court, District of Columbia, Judge Royce C. Lamberth. Decided . Read the opinion
The court applied the reductions below but did not state requested and awarded totals we could check against the opinion, so no overall percentage is shown.
ERISA benefits · ERISA · Fee applicant's counsel: Proskauer Rose LLP
What happened
The Trustees of the IAM National Pension Fund, represented by Proskauer Rose LLP, sought a supplemental fee award in ERISA benefits litigation. The court voided 13.5 attorney hours spent on e-filing and reduced the recovery by $8,640, leaving the remainder of the e-filing entries, billed at proper rates, intact. It also cut a subset of entries by 20%, or $23,823.36, to bring the cost per unit of time into alignment with the rest of the dispute. The court did not state totals.
What the court said
The Court will therefore void the 13.5 attorney hours spent on e-filing and reduce the final recovery by $8,640, but leave the remainder of the e-filing entries, billed at proper rates, intact.
The court also reduced the award for: excessive hours.
Why it matters
The ruling shows courts separate clerical tasks such as e-filing from legal work and will strike hours billed at attorney rates for them. It also shows courts may apply a percentage cut to a subset of entries to align billing with the rest of a case, even without a line-by-line review.
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
TRUSTEES OF THE IAM NATIONAL PENSION FUND v. M & K EMPLOYEE SOLUTIONS, LLC, No. 1:20-cv-00433 (D.D.C. Sept. 30, 2024) See hourly rates the District of Columbia approves and attorney fee motions in District of Columbia 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.
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