S.D. Florida cuts commercial fee award 46%, including for vague entries

What happened

Valley National Bank sought $464,258.50 in fees and costs under a contract fee clause, covering 772.4 hours. The court awarded $250,730, a reduction of $213,528.50 or 46%. It lowered hourly rates for several attorneys and paralegals, including a partner not licensed in Florida, and reduced time for vague and heavily redacted entries, block billing, duplicative staffing, excessive hours, and limited success.

What the court said

At the outset, many entries are so heavily redacted that it is impossible to understand the work the attorney performed, thereby making the entries vague.

Second, many of the entries contain block billing.

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

Why it matters

The ruling shows that a fee applicant's time records are central to the award. Entries too redacted to show the work, block billing, and duplicative staffing led to cuts even where the court accepted that some time was recoverable, and the court also weighed the overall reasonableness of the hours against the scope of the litigation.

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.