N.D. California cuts consumer protection fee award 61.5%, including for clerical work

What happened

The fee applicant sought $37,462.50 for 79.5 hours in Yarovoy v. Tesla Motors, Inc. The court awarded $14,436.25, a reduction of $23,026.25 or 61.5%. It cut hours spent drafting the complaint to five total, deducted all 9.7 hours on the auto warranty complaint, reduced fees by $845 for clerical work billed as legal work, and applied a 50% deduction to a subset of entries for internal work, citing excessive hours and vague entries.

What the court said

The Court reduces the attorney s fees award by $845,

the Court makes a 50% deduction of counsel s $5,207.50 in excessive billing for internal

The court also reduced the award for: excessive hours, other, excessive hours.

Why it matters

The ruling shows courts will separate clerical tasks from legal work and reduce entries that lack specificity, and will trim hours the court considers excessive even when the total requested is modest. It also shows reductions can be applied to subsets of entries rather than the whole fee request.

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

See hourly rates the N.D. California approves and attorney fee motions in California 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.