Beckwith v. District of Columbia, 254 F. Supp. 3d 1

Plaintiffs Javanda Beckwith and her minor child L.B. filed an IDEA challenge after an administrative hearing officer denied relief, alleging multiple failures by D.C. Public Schools to provide a FAPE (implementation of June 2014 and Jan 2015 IEPs, inappropriate placement, reduced services, delayed behavioral plan, improper restraint use).
This Court (adopting a magistrate judge recommendation) in 2016 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; it ordered revision of the IEP and compensatory education.
Plaintiffs moved for attorneys’ fees seeking $72,160.86; the District contested the amount and certain billed tasks.
The parties agreed to use the 75% Laffey rate and a 15% reduction for limited success, but disagreed about reimbursement for (1) time spent on MDT/IEP meetings and (2) paralegal-rate billing for clerical/support staff tasks.
The Court found plaintiffs were prevailing parties and awarded fees, making specific reductions: disallowing certain IEP-meeting time, reducing mixed entries, and cutting support-staff time by 50%.
Final award: $62,154.62 in fees and costs to plaintiffs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs are prevailing parties entitled to fees	Prevailing party entitled to fees after successful IDEA claims and court-ordered relief	Implicitly conceded prevailing-party status not disputed	Court: plaintiffs are prevailing parties; fees available under IDEA
Proper hourly rate and overall reduction	Use 75% Laffey rates; apply 15% reduction for limited success	Agreed on 75% Laffey and 15% reduction but disputed specific billed items	Court adopted 75% Laffey and 15% reduction for limited success
Recoverability of time for MDT/IEP meetings and related preparation	Time addressing implementation/enforcement is compensable; pure IEP meeting preparation is not	Time spent on MDT/IEP meetings is non-compensable	Court: disallowed pure meeting prep; allowed implementation-related time; reduced mixed entries (50% on one) resulting in recovery of 0.25 hours ($86.25 pre-reduction)
Compensation for tasks by non-attorney support staff (Teel and Athey)	Billed at paralegal rates; some tasks were substantive and compensable	Many entries are clerical/secretarial and thus non-compensable	Court: could not parse each entry, so reduced total support-staff time by 50%; awarded $947.14 for that time after reduction

D.C. v. Straus, 590 F.3d 898 (D.C. Cir.) (definition of prevailing party for fee awards)
Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir. 2015) (lodestar analysis and factors for reasonable rate)
Laffey v. Northwest Airlines, 572 F. Supp. 354 (D.D.C. 1983) (origin of the Laffey Matrix)
Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (reducing fee awards for limited success)
Joaquin v. D.C., 210 F. Supp. 3d 64 (D.D.C. 2016) (discussion of Laffey matrix variants)
Snead v. District of Columbia, 139 F. Supp. 3d 375 (D.D.C. 2015) (use of reduced Laffey rates in IDEA cases)
A.S. v. D.C., 842 F. Supp. 2d 40 (D.D.C. 2012) (IEP meeting prep time non-compensable)
Shaw v. D.C., 210 F. Supp. 3d 46 (D.D.C. 2016) (fees for implementing/enforcing relief may be compensable)
Jackson v. D.C., 603 F. Supp. 2d 92 (D.D.C. 2009) (clerical tasks non-compensable)
Irving v. D.C. Pub. Sch., 815 F. Supp. 2d 119 (D.D.C. 2011) (examples of clerical vs. substantive support tasks)
Johnson v. D.C., 850 F. Supp. 2d 74 (D.D.C. 2012) (client correspondence can be compensable)
Baker v. D.C. Pub. Sch., 815 F. Supp. 2d 102 (D.D.C. 2011) (paralegal substantive tasks compensable)
Driscoll v. George Washington Univ., 55 F. Supp. 3d 106 (D.D.C. 2014) (compensable tasks include drafting correspondence and witness interviews)
Bailey v. D.C., 839 F. Supp. 888 (D.D.C. 1993) (examples of compensable non-attorney work)
Michigan v. U.S. EPA, 254 F.3d 1087 (D.C. Cir. 2001) (filing is clerical and non-compensable)