Gardill v. District of Columbia
2013 U.S. Dist. LEXIS 34816
| D.D.C. | 2013Background
- Plaintiffs seek attorneys’ fees under IDEA for twelve students' administrative proceedings against DCPS.
- Plaintiffs request full Laffey rates; District argues DCPS guidelines should cap fees at lower rates.
- Magistrate Judge Kay recommended fees at three-quarters of Laffey rates; full Laffey rates denied except for two cases.
- Court holds complexity varies by case; most cases are straightforward, justifying reduced rates, while C.G. and D.G. are sufficiently complex for full Laffey rates.
- Each student case involved administrative hearings with multiple exhibits and witnesses; some involved two-day hearings and settlements.
- Overall, cross-motions for summary judgment granted in part and denied in part; three-quarters Laffey rates Apply except C.G. and D.G.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether three-quarters of Laffey rates are appropriate | Gardill plaintiffs argue Laffey rates are appropriate as standard IDEA fees. | District contends DCPS guidelines or lower rates should apply due to case simplicity. | Three-quarters of Laffey rates are generally appropriate. |
| Whether C.G. and D.G. warrant full Laffey rates | C.G. and D.G. involved complexity justifying full Laffey rates. | District argues most cases are straightforward; full rates only for complex matters. | Full Laffey rates justified for C.G. and D.G. |
| Whether DCPS fee guidelines govern the award | Laffey matrix should control; guidelines are inappropriate for IDEA complexity. | DCPS guidelines should govern and plaintiffs already reimbursed under them. | Laffey-based rates prevail except as to the C.G. and D.G. cases; guidelines not controlling overall. |
Key Cases Cited
- Rooths v. District of Columbia, 802 F. Supp. 2d 56 (D.D.C. 2011) (complexity may justify higher rates in IDEA fees)
- Rempson v. District of Columbia, 802 F. Supp. 2d 153 (D.D.C. 2011) (Laffey matrix as benchmark for IDEA fees; some cases presumptively reasonable)
- A.C. ex rel. Clark v. District of Columbia, 674 F. Supp. 2d 149 (D.D.C. 2009) (matrix inapplicable where routine hearings; rely on typical rates)
- In re North, 59 F.3d 184 (D.C. Cir. 1995) (judicial standard for reasonableness of hours and rates)
- Hensley v. Eckerhart, 461 U.S. 424 (U.S. Supreme Court 1983) (fee must reflect reasonable hours times reasonable rate)
- Bucher v. District of Columbia, 777 F. Supp. 2d 69 (D.D.C. 2011) (reasonable fee depends on reasonable hourly rate and hours)
- Rapu v. D.C. Pub. Sch., 793 F. Supp. 2d 419 (D.D.C. 2011) (use of Laffey matrix as benchmark for IDEA fees)
- McClam v. District of Columbia, 808 F. Supp. 2d 184 (D.D.C. 2011) (complexity-based fee adjustments in IDEA)
- McNeil v. Options Pub. Charter Sch., Not cited with official reporter in text (D.D.C. 2013) (full Laffey rates in select complex cases (WL not allowed))