S.D. Alabama cuts fee award 64.4%, including for clerical work
UNITED STATES OF AMERICA et al v. Pathway of Baldwin County, LLC et al, No. 1:17-cv-00355. District Court, S.D. Alabama, Judge Kristi K. DuBose. Decided . Read the opinion
- Requested
- $1,110,730
- Awarded
- $395,287.50
- Cut
- 64.4%$715,442.50
What happened
The fee applicant sought $1,110,730 in attorney fees. The court awarded $395,287.50, a reduction of $715,442.50. It reduced the attorney's 2,117.80 hours by about 50% to 1,058 hours for excessive and duplicative work, fees on fees, unrelated claims, and time entries reflecting non-recoverable clerical work, and reduced the hours of three paralegals by about 35%.
What the court said
there are time entries which reflect non-recoverable clerical work
The court also reduced the award for: hourly rate reduced, excessive hours, duplicative staffing, fees on fees, unrelated claims, excessive hours, excessive hours, excessive hours.
Why it matters
The ruling shows that a fee award can be cut sharply when time entries mix clerical tasks with legal work and when hours are duplicative or spent on non-compensable matters. Courts review entries line by line and apply percentage reductions rather than awarding the requested amount.
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
UNITED STATES OF AMERICA v. Pathway of Baldwin County, LLC, No. 1:17-cv-00355 (S.D. Ala. Mar. 21, 2025) See hourly rates the S.D. Alabama 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.
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