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Their fees, therefore, could be included in an award for attorney fees.

The Arizona Supreme Court upheld the portion of the judgment that allowed law clerk and paralegal fees to be included with attorney fees, stating that such individuals have typically acquired legal training and knowledge sufficient to permit them to contribute substantively to an attorney’s analysis and preparation of a case.

Bach appealed the decision, arguing that certain costs, including those for tasks performed by non-attorney staff members, were not ‘attorney fees’ and therefore could not be recovered pursuant to an award for attorney fees. Bach”) for violating certain restrictions for its neighborhood, and won, the Court awarded Ahwatukee attorneys fees which included law clerk and paralegal time. After Ahwatukee Custom Estates Management Association (“Ahwatukee”) brought suit against homeowner, Daniel Bach (“Mr. What is the distinction between billable and non-billable hours? The appellate Courts in Arizona weighed in on this issue in Ahwatukee Custom Estates v.Bach, 973 P.2d 106 (Ariz 1999). In contrast, time spent making copies, talking to potential clients, or preparing invoices is non-billable time.

Time spent conducting research, preparing pleadings, or speaking with opposing counsel about a case is billable time. Billable hours are those hours worked by a service provider, such as an attorney or paralegal that is directly billable to a client.