Adams v. District of Columbia
Civil Action No. 2003-2139
| D.D.C. | Jun 16, 2017Background
- This opinion is an appendix and calculations accompanying the District Court’s memorandum resolving disputes over attorney-fee, cost, and post-judgment interest payments in multiple consolidated cases against the District of Columbia.
- Magistrate Judge Harvey prepared a Report & Recommendation (R&R) showing amounts due (fees, costs, interest) for several HOD-based fee judgments; the District and plaintiffs each disputed parts of his computations and allocations of payments.
- Key disputes: whether interest should be calculated on full judgment amounts or only on amounts limited by $4,000 per HOD fee caps; correct interest rates to apply; allocation of undated post-judgment payments between fees/costs/interest; and whether additional fee caps apply in particular cases (notably Bradley and Adams).
- The Court corrected numerical and rate errors in the R&R for AC (Clark) and Wingfield, accepted that plaintiffs are owed an additional $20,000 in Bradley, rejected many plaintiffs’ additional fee/cost claims, and rejected the District’s approach of calculating interest only on capped amounts.
- The Court recalculated interest using 28 U.S.C. § 1961 methodology (annual compounding using weekly average 1‑year Treasury yield preceding each judgment) and allocated post-judgment payments consistent with the record; it ordered return of a $533.19 overpayment in Thomas.
- Final aggregated amounts the opinion reports as due (per the Court’s recalculation): remaining fees $219,913; remaining costs $779; remaining interest $1,442,840.32.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper principal for calculating post-judgment interest | Interest should be computed on the amounts plaintiffs claim remain due (effectively full judgments) | Interest should be calculated only on amounts owed under the $4,000-per-HOD fee caps | Court held interest must be computed on the full remaining judgment balances (not limited to claimed fee-cap amounts) following 28 U.S.C. § 1961 |
| Correct interest rates and accrual periods | Plaintiffs argued certain rates/dates used by Magistrate Judge Harvey were incorrect and that interest continued accruing past certain dates | District used different rates (and in some cases used amounts post-cap) and claimed interest largely paid | Court corrected erroneous rates for AC (Clark) and Wingfield, fixed accrual end dates (generally Nov. 9, 2016; July 15/17, 2017 for unpaid Adams/Bradley), and recalculated interest accordingly |
| Allocation and crediting of undated post-judgment payments | Plaintiffs contended no post-judgment credits should be subtracted when payments were undated or not clearly allocable | District sought crediting those payments and argued it had paid in full in many cases | Court allocated payments according to the record, credited amounts where supported, and rejected plaintiff arguments that no credits should be applied absent dates |
| Application of fee caps and additional fee claims (e.g., Bradley, Adams) | Plaintiffs sought additional fees in several cases (notably $20,000 in Bradley; more in Adams/Abraham/AC) | District disputed those additional fee demands and argued substantial payments should reduce fees owed | Court awarded plaintiffs an additional $20,000 in Bradley (finding six HODs) but rejected other additional fee/cost claims; also rejected District’s claim that certain large payments satisfied Adams obligations |
Key Cases Cited
- Jefferson v. Milvets Sys. Tech., Inc., 986 F. Supp. 6 (D.D.C. 1997) (discussing timing and compounding of post-judgment interest under § 1961)