DL v. Dist. of Columbia, Corp., 924 F.3d 585

Plaintiffs (parents of DC children) won a complex, long-running IDEA class-action against the District of Columbia; the district court awarded attorneys’ fees and the District appealed only the hourly-rate determination.
Fee awards under IDEA must be based on “rates prevailing in the community . . . for the kind and quality of services furnished,” 20 U.S.C. § 1415(i)(3)(C); the lodestar is hours × reasonable hourly rate.
D.C. practice commonly uses the Laffey matrix (original 1983 and a 1989 update) as a starting point for rates for complex federal litigation, with various inflation updates (e.g., Legal Services Index).
The USAO created a new matrix from ALM’s 2011 Survey of Law Firm Economics for the broader Washington, D.C. metro area (all practice areas), producing substantially lower average rates.
The district court accepted the USAO matrix over plaintiffs’ LSI-updated Laffey matrix and reduced the fee award from about $9.76M to $6.96M; plaintiffs appealed the rate choice.
The D.C. Circuit vacated and remanded, holding the USAO matrix is not a proper benchmark because it surveys the wrong types of lawyers and the wrong geographic community (metro area outside D.C.).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs met initial burden to justify Laffey (LSI) rates	Laffey (LSI-updated) evidence suffices to justify rates; burden shifts to District	Plaintiffs failed to show specific market rates	Court: Plaintiffs met the burden (Salazar precedent); burden shifted to District
Whether the USAO matrix rebuts plaintiffs’ showing	N/A	USAO matrix is superior because newer, larger sample, narrower experience bands	Court: USAO matrix fails—data include non-litigators and a broad metro area outside D.C., so it does not measure rates for the relevant community/type of services
Appropriate community and comparator lawyers for IDEA class complex federal litigation	Use rates for complex federal litigators in District of Columbia (LSI Laffey)	Use broader metro-area, all-practice survey (USAO matrix)	Court: Rates must reflect lawyers doing the same type/quality of complex federal litigation in the community where the action arose (D.C.); USAO matrix does not satisfy that statutory requirement
Whether Cyrus Mehri is entitled to his usual private billing rate	Mehri claims a higher private billing rate	District used same methodology as for other counsel	Court: No basis to depart; compensating Mehri at same market-based method as co-counsel was not an abuse of discretion

National Association of Concerned Veterans v. Secretary of Defense, 675 F.2d 1319 (D.C. Cir. 1982) (earlier direction on proving market rates)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (avoid turning fee calculation into second major litigation)
Blum v. Stenson, 465 U.S. 886 (1984) (reasonable fees = rates prevailing in the community for similar services)
Laffey v. Northwest Airlines, Inc., 572 F. Supp. 354 (D.D.C. 1983) (origin of the Laffey matrix for complex federal litigation)
Save Our Cumberland Mountains, Inc. v. Hodel, 857 F.2d 1516 (D.C. Cir. 1988) (commending Laffey matrix use and updates)
Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir. 1995) (burden-shifting framework; matrices as starting points)
Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir. 2015) (focus on comparators doing the same type of litigation)
Salazar v. District of Columbia, 809 F.3d 58 (D.C. Cir. 2015) (LSI-adjusted Laffey supported by record; burden-shifting application)
Reed v. District of Columbia, 843 F.3d 517 (D.C. Cir. 2016) (distinguishing individual administrative IDEA cases from complex federal litigation)
Kattan ex rel. Thomas v. District of Columbia, 995 F.2d 274 (D.C. Cir. 1993) (reversal standard for fee-rate findings)
Anderson v. Bessemer City, 470 U.S. 564 (1985) (Rule 52(a) clear-error standard for factual findings)