Substantiation Of Reasonableness Of Fees: Block Billing Was No Reason To Reduce Fee Request Where No Apportionment Required

Practice Is Not Objectionable Per Se.

     1800 – 1840.  Library of Congress.

     The Fifth District in F.W. Spencer & Son, Inc. v. Harris Construction Co., Inc., Case Nos. F064782/F064793 (5^th Dist. Feb. 26, 2014) (unpublished) sustained a contractual attorney’s fees award of $557,212.50 despite the appellant’s challenge that block billing should result in a 10-30% reduction of the entire bill.

     In this regard, the reviewing court found block billing is not objectionable per se, and especially less objectionable if there is no need to apportion out compensable from non-compensable work. (Jaramillo v. County of Orange, 200 Cal.App.4^th 811, 830 (2011); Bell v. Vista Unified School Dist., 82 Cal.App.4^th 672, 689 (2000).) Because no apportionment was needed in this case, no reduction in billing was needed on for block billing entries—although the appellate court did note this is a discretionary function of the lower court reviewable upon appeal.