D. Arizona cuts wage and hour fee award 5.3% over clerical work

What happened

The plaintiff in a Fair Labor Standards Act wage and hour case asked the District of Arizona for $21,664 in attorney fees for 46.2 hours. Judge Diane J. Humetewa awarded $20,516.50, a reduction of $1,147.50, or 5.3%. The court removed 1.7 hours billed for administrative or clerical tasks and 0.3 hours for entries it found lacked clarity and support, leaving 43.7 compensable hours. The figures do not include costs.

What the court said

the Court will excise time entries that are administrative or clerical tasks

the following entries lack clarity and support, and will therefore be subtracted from counsel’s total hours eligible for attorney fees

Why it matters

The ruling shows that courts will subtract time for tasks that are administrative or clerical even when they appear in an attorney fee request, and will also cut entries that do not clearly describe the work performed. Fee applicants should expect line-by-line review of time records.

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 D. Arizona approves and attorney fee motions in Arizona 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.