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 lowered the hourly rates for the associate, senior attorney, partner, and paralegal. It cut by one third time charged for simple tasks, struck 2.9 paralegal hours as clerical, and reduced hours for vague entries and duplicative staffing, awarding 31.1 hours. No dollar totals were stated.

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, hourly rate reduced, excessive hours, duplicative staffing.

Why it matters

The ruling shows that courts will reduce hours when time entries do not describe the work with enough specificity, when staffing is duplicative, and when clerical tasks are billed as legal work, even under a contract fee clause.

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.