COURT STRIKES AWARD FOR ATTORNEYS’ FEES BASED ON BLOCK BILLING AND VAGUE AND DUPLICATIVE ENTRIES

Nova Southeastern v. Garrett-Callahan Co., 50 Fla. L. Weekly D2247 (Fla. 4th DCA Oct. 15, 2025):

This case arose from breach of contract and professional negligence claims against an engineering company. There were multiple defendants. Based on entitlement from nonbinding arbitration, the plaintiff sought attorneys’ fees against the remaining defendant.

The appellate court affirmed the trial court’s finding that the claims against the defendants were not inextricably intertwined to allow for the award of attorneys’ fees.

However, the appellate court reversed the trial court’s attorneys’ fee awards based on block billing, duplicative billing and vague entries. The plaintiff’s  fee expert conceded that reductions were warranted, recommending a 10% reduction for block billing and a 5% reduction for vague and duplicative entries.

The appellate court reversed, concluding that a random, blanket percentage reduction was insufficient and required reversal. The court remanded for reconsideration of the fee award based on the specific hours billed and the sufficiency of the work descriptions.