
Judge Liman: Blake Lively Attorney Fees Blunderbuss Slashed
Summary
- Actress Blake Lively was awarded $407,452 in attorney fees and costs, a significant reduction from her $8 million request.
- U.S. District Judge Lewis J. Liman cited "flawed paperwork" and a "blunderbuss approach" for the reduction.
- The award covered only reasonable fees for defending against defamation, not all litigation costs from the "It Ends With Us" case.
- Lively's legal teams, Willkie Farr & Gallagher and Manatt, Phelps & Phillips, had billed nearly $7.5 million.
- The judge referenced California Civil Code Section 47.1, noting its ambiguity regarding fee scope for prevailing defamation defendants.
What Happened in the Southern District of New York
Lively's blunderbuss approach leaves the court no way to determine precisely how many hours were reasonably incurred on common issues.
A federal judge in New York significantly reduced actress Blake Lively's request for attorney fees and court costs, awarding her just $407,452 out of the $8 million she had sought. The ruling, issued on a Wednesday, August 27, 2026, by U.S. District Judge Lewis J. Liman of the Southern District of New York, highlighted "flawed paperwork" and a "blunderbuss approach" in the submitted documentation. Lively had pursued these costs from her "It Ends With Us" co-star and director, Justin Baldoni, and his company, Wayfarer Studios, following litigation stemming from alleged sexual harassment on the set of the 2024 romantic drama.
Lively's initial request included $7.5 million for attorney fees and an additional $540,000 for expenses. Her legal representation involved two prominent firms: Willkie Farr & Gallagher, which billed approximately $4.5 million, and Manatt, Phelps & Phillips, whose services cost just under $3 million. Ultimately, Judge Liman awarded Lively $363,245.40 for attorney fees and $44,206.35 for expenses. This substantial reduction underscores the court's rigorous scrutiny of litigation costs, particularly when requests lack precise justification. Lively herself had appeared in court on February 11, 2026, to explore potential settlement options for the lawsuit before a scheduled May trial.
Judicial Scrutiny and the 'Blunderbuss Approach'
Judge Liman's decision to drastically cut the requested Blake Lively attorney fees was rooted in the lack of specificity in the billing submissions. He concurred with Baldoni and Wayfarer Studios that Lively was only entitled to reasonable fees and necessary costs directly related to her defense against defamation claims, rather than all expenses incurred throughout the entire litigation. The judge explicitly criticized what he termed Lively's "blunderbuss approach," stating that it left the court unable to determine precisely how many hours were reasonably incurred on common issues.
The court also considered California Civil Code Section 47.1 in its analysis of the defamation attorney fees. Judge Liman noted that this statute, which he described as "ambiguous," entitles a prevailing defendant in a defamation case to reasonable attorney's fees and costs, though the specific determination of what constitutes 'reasonable' often requires judicial interpretation. This ambiguity further necessitated a clear and detailed breakdown from Lively's legal team, which the court found to be lacking. The ruling serves as a stark reminder that even in high-profile cases involving significant It Ends With Us litigation costs, courts will not rubber-stamp fee requests without adequate justification.
Why Meticulous Billing Matters
This ruling from the Southern District of New York highlights a crucial lesson for legal practitioners: the importance of meticulous itemization in attorney fee requests. The significant Judge Liman attorney fee reduction demonstrates that courts are increasingly unwilling to approve broad, undifferentiated billing, especially when faced with a "blunderbuss approach" that obscures the direct link between services rendered and successful legal outcomes. For firms like Willkie Farr and Manatt Phelps, this case underscores the need for stringent internal billing practices that anticipate judicial scrutiny.
The outcome in Lively's case reinforces the principle that only reasonable and necessary costs directly tied to specific, prevailing claims are recoverable. Legal teams must be prepared to justify every hour and expense, providing clear documentation that allows a court to easily distinguish between work performed for successful defenses and general litigation efforts. Failure to do so, as demonstrated by this substantial fee cut, can lead to a significant disparity between the fees billed to a client and the amount ultimately awarded by a court.
Practical Implications
Lawyers must meticulously itemize attorney fee requests, clearly linking hours and expenses to specific successful claims, to avoid significant reductions by courts that scrutinize 'blunderbuss' or unspecific billing practices, as demonstrated by this substantial fee cut.
Source
Source: Original reporting via Law360
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