S.D. Florida cuts commercial fee award, including for vague entries

What happened

Bradley Arant Boult Cummings LLP sought fees under a contract fee clause for 42.8 hours. The court reduced the hourly rates for the associate, the senior attorney, and the partner, finding the charged rates excessive. It cut by one third time entries it found excessive for simple tasks, and reduced hours for vague entries, duplicative staffing, unexplained initials, and 2.9 paralegal hours it found clerical. The court awarded 31.1 hours.

What the court said

Other time entries are vague (i.e., time entry titled "attention to filing of motion for default judgment" for .3 hour and "communications and related analysis to finalize Florida complaint" for .7 hours).

the paralegal's 2.90 hours should be stricken as clerical in nature

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

Why it matters

The ruling shows that courts will reduce fee awards when time entries lack detail, repeat work across timekeepers, or bill clerical tasks as legal work. Even without stating totals, the court applied several separate reductions, signaling that specific, nonduplicative entries are needed to support a fee request.

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 S.D. Florida approves and attorney fee motions in Florida 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.