Douglas v. District of Columbia, 2014 U.S. Dist. LEXIS 122920

Background

Plaintiff Jayshawn Douglas, an 18-year-old IDEA-eligible student classified as “Other Health Impaired,” alleged DCPS blocked his attendance at his IEP placement (Twilight Program at Dunbar) in Fall 2013.
Douglas filed an administrative due process complaint and, before resolution, sued in federal court under 20 U.S.C. § 1415(j) (stay-put) and 42 U.S.C. § 1983 and moved for a preliminary injunction seeking enforcement of stay-put.
The District initially excluded Douglas from Dunbar; on November 14, 2013 the court granted a preliminary injunction (stay-put), ordering reenrollment and halting any transfer.
Douglas moved for attorneys’ fees and costs of $25,499.65 for work obtaining the stay-put order; the District opposed, arguing no prevailing-party status, lower hourly caps (including a $90 Superior Court rate), and reductions to hours and rates.
The court found Douglas to be the prevailing party for the §1415(j) claim, applied a 3/4 Laffey cap to hourly rates (for routine IDEA matters), disallowed fees solely tied to administrative proceedings or dismissed §1983 claims, compensated travel at half-rate, and reduced certain other entries.
Final award: $16,034.00 in attorneys’ fees and $975.62 in costs (total $17,009.62), payable by the District.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Douglas is a "prevailing party" entitled to IDEA fees	Douglas obtained full relief on his §1415(j) claim via court-ordered stay-put	District: stay-put is interim/status-quo and not a change in legal relationship; no merits decision	Court: Douglas is a prevailing party — preliminary injunction/stay-put altered legal relationship and afforded requested relief
Appropriate hourly rates	Requested Laffey Matrix rates ($510; $250; $250) as prevailing-market rates	District: cap at $90 under D.C. Code §11-2604(a) because attorneys were Superior Court-appointed	Court: Superior Court cap inapplicable; applied 3/4 of Laffey rates as presumptive cap for routine IDEA matters ($382.50; $187.50)
Whether billed hours should be reduced for work outside federal claim	Fees for work directly obtaining/enforcing stay-put are recoverable	District: exclude hours tied solely to administrative process or post-order work	Court: disallowed fees solely for the administrative due process (unless later successful there); allowed enforcement/post-order work; reduced entries tied to non-prevailing §1983 claim; travel billed at half-rate
Whether litigation was unreasonably protracted warranting fee reduction	Douglas contended stay-put suits may proceed in federal court without administrative exhaustion	District: filing federal complaint before exhausting administrative remedies unreasonably protracted resolution	Court: rejected reduction — statutory stay-put exception permits federal action and District did not show administrative route would be quicker or less work

Key Cases Cited

Hensley v. Eckerhart, 461 U.S. 424 (fee award lodestar framework)
Buckhannon Bd. & Care Home, Inc. v. West Virginia Dept. of Health & Human Res., 532 U.S. 598 (changes in legal relationship and judicially sanctioned relief for prevailing-party status)
Turner v. Nat’l Transp. Safety Bd., 608 F.3d 12 (D.C. Cir.) (prevailing-party status can include preliminary injunctions and other judicial relief)
Jeppsen ex rel. Jeppsen v. Dist. of Columbia, 514 F.3d 1287 (D.C. Cir.) (judicially-sanctioned relief can create prevailing-party status)
Covington v. Dist. of Columbia, 57 F.3d 1101 (D.C. Cir.) (courts’ treatment of reasonable rates and lodestar; caution on Laffey applicability)
In re Olson, 884 F.2d 1415 (D.C. Cir.) (documentation and detail required to support fee awards)
Drinker by Drinker v. Colonial Sch. Dist., 78 F.3d 859 (3d Cir.) (stay-put functions as automatic preliminary injunction)
Cooper v. United States R.R. Retirement Bd., 24 F.3d 1414 (D.C. Cir.) (travel time compensated at half hourly rate)