BECKWITH v. DISTRICT OF COLUMBIA, 1:15-cv-01284

Plaintiff Javanda Beckwith and her minor child L.B. sued the District of Columbia under the IDEA, challenging DCPS's implementation of L.B.’s June 2014 and January 2015 IEPs and related restraint and behavioral plan practices.
An administrative hearing officer denied plaintiffs relief; plaintiffs appealed to federal court in 2015.
This Court (adopting a magistrate judge recommendation) found DCPS denied L.B. a FAPE by failing to implement the June 2014 and January 2015 IEPs and by failing to follow restraint requirements, and ordered remedial relief including compensatory education.
Plaintiffs moved for attorneys’ fees under 20 U.S.C. § 1415(i)(3); they sought $72,160.86. The Court evaluated entitlement and reasonableness under IDEA fee-shifting standards.
Parties agreed to use 75% of the Laffey rates and a 15% reduction for limited success; disputes remained about (1) recoverability of time spent on MDT/IEP meetings and (2) billing for clerical/secretarial tasks by non-attorney staff.
The Court awarded plaintiffs $62,154.62 after adjustments: reimbursement for time spent in district-court litigation, partial disallowance of IEP/MDT meeting time, and a 50% reduction of certain non-attorney time.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs are prevailing parties entitled to fees	Beckwith argued the court-ordered reversal and relief made them prevailing parties under IDEA	D.C. did not contest prevailing-party status	Court found plaintiffs prevailing parties and entitled to fees under Straus framework
Appropriate hourly rates / market standard	Plaintiffs supported using 75% of the Laffey matrix rates	Defendant agreed to 75% Laffey; rate disputes limited to specific entries	Court adopted 75% Laffey rates for fee calculation
Recoverability of time spent on MDT/IEP meetings	Plaintiffs sought recovery for limited entries involving meeting preparation and implementation discussions	D.C. argued MDT/IEP meeting preparation and attendance is non-compensable	Court disallowed pure meeting-related time, allowed time for implementation tasks; reduced a mixed entry by 50% and awarded a small recoverable amount
Billing for tasks by non-attorney staff (Teel and Athey)	Plaintiffs billed those staff at paralegal rates for administrative and substantive tasks	D.C. argued many entries were clerical/secretarial and non-compensable	Court declined to parse each entry; reduced total time for those staff by 50% and awarded half of billed amount

D.C. v. Straus, 590 F.3d 898 (D.C. Cir.) (prevailing-party standard under IDEA)
Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir.) (lodestar framework and factors for reasonable rate)
Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (limited success and proportional reduction principles)
Laffey v. Northwest Airlines, Inc., 572 F. Supp. 354 (D.D.C. 1983) (origin of Laffey matrix for prevailing market rates)
Jackson v. District of Columbia, 603 F. Supp. 2d 92 (D.D.C. 2009) (clerical tasks not compensable)
Michigan v. U.S. E.P.A., 254 F.3d 1087 (D.C. Cir. 2001) (examples of clerical functions not compensable)
A.S. v. District of Columbia, 842 F. Supp. 2d 40 (D.D.C. 2012) (IEP meeting preparation and attendance generally non-compensable)
Shaw v. District of Columbia, 210 F. Supp. 3d 46 (D.D.C. 2016) (fees allowed for work enforcing or implementing orders)