Block Billing Criticisms Are Fair, Depending On The Circumstances.
Simons v. Superior Court, Case No. B309885 (2d Dist., Div. 3 Mar. 25, 2022) (unpublished) is a situation where the appellate court affirmed a Civil Code section 1717 fee award, even with high hourly rates and block billing, when the fee factual finder awarded $170,000 after reducing the requested fees by $64,000. The appellate court confirmed that criticisms of block billing were justified, but its application depends on the nature of the billings. The fee finder’s reductions were ample such that nothing more needed to change.
Comments