Blackman v. District of Columbia
239 F. Supp. 3d 22
| D.D.C. | 2017Background
- Plaintiffs obtained a court order on August 5, 2004 awarding attorneys’ fees and costs under the IDEA: $12,894.23 to Blackwell, $10,964.53 to Harris, and $4,528.34 to Timmons.
- Congressional appropriations placed a cap on D.C.’s IDEA fee liability; defendants paid amounts limited by the cap (roughly $4,300, $4,205, and $4,154 respectively), leaving unpaid balances plus interest.
- Plaintiffs moved on July 15, 2016 to revive the 2004 decree under D.C. Code § 15-103, within the 12-year enforcement period that expired August 5, 2016.
- Defendants conceded they owe the outstanding sums but stated they could not pay more due to the statutory cap; they did not oppose revival procedurally.
- The court treated the 2004 Opinion and Order as a judgment for purposes of D.C. Code § 15-101 and considered whether to extend its enforceability for another 12 years.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 2004 money decree may be revived under D.C. Code § 15-103 | Motion to revive filed within 12-year period; revival permissible | No opposition to revival; concedes outstanding debt but cites statutory cap as payment constraint | Revival granted; enforceability extended 12 years from order date |
| Whether Congress’ cap on D.C. IDEA fee payments bars revival or enforcement | Revival appropriate despite cap; seeks ability to enforce the judgment | Cap limits what D.C. can pay now; thus cannot pay full award | Court found no authority requiring denial; revival not barred by cap (defendant still may be unable to pay beyond cap) |
Key Cases Cited
- Blackman v. Dist. of Columbia, 328 F. Supp. 2d 36 (D.D.C. 2004) (original fee award underlying revival motion)
- Whatley v. Dist. of Columbia, 447 F.3d 814 (D.C. Cir. 2006) (discussing Congress’ cap on D.C. IDEA fee payments)
- Allen v. Dist. of Columbia, 128 F. Supp. 3d 74 (D.D.C. 2015) (treating the court’s order as a judgment under D.C. enforcement provisions)
- Mayo v. Mayo, 508 A.2d 114 (D.C. 1986) (statutory 12-year enforcement/revival framework)
- Nat’l Bank of Wash. v. Carr, 829 A.2d 942 (D.C. 2003) (timeliness of revival motion governs renewal after enforcement period)
- Michael v. Smith, 221 F.2d 59 (D.C. Cir. 1955) (courts should revive where defendant offers no defense to revival)