By: Scott B. Riddle, Esq.
There is a split of authority regarding whether clerical or secretarial work is compensable. Compare, e.g., Walker v. United States Dep’t of Housing and Urban Development, 99 F.3d 761, 770 (5th Cir.1996) ("Clerical work, however, should be compensated at a different rate from legal work."), with, e.g., Surge v. Massanari, 155 F.Supp.2d 1301, 1307 (M.D.Ala.2001) ("requests for . . . non-compensable clerical tasks [are] inappropriate").
Consistent with what appears to be the great majority of courts within the Eleventh Circuit that have considered that issue, this Court concludes that Plaintiff is not entitled to any reimbursement for clerical or secretarial tasks that Plaintiff’s counsel performed.