Gray v. District of Columbia
2011 U.S. Dist. LEXIS 44556
| D.D.C. | 2011Background
- Plaintiff Paula Gray is the parent of a DCPS student and sought fees under IDEA §1415(i)(3)(B) after a successful administrative hearing finding DCPS failed to provide FAPE.
- Plaintiff filed a due process complaint on November 12, 2008; the Hearing Officer ruled in her favor on February 16, 2009.
- Plaintiff submitted a petition for attorneys' fees and costs seeking $8,240.60; Defendants reimbursed $2,357.80, leaving $5,882.80 outstanding.
- Plaintiffs filed suit in DC Superior Court on August 20, 2009; Defendants removed to this court on September 18, 2009.
- Court granted Plaintiff’s Motion for Leave to Amend and then denied Plaintiff’s Motion for Summary Judgment after considering briefs and record.
- Court ultimately denies Plaintiff’s Motion for Summary Judgment and limits recovery to the amounts already paid under DCPS Guidelines.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff’s fee petition is reasonable under IDEA | Gray seeks reasonable fees based on hours and rates | Defendants challenge reasonableness and detail of entries | Denied; fees not proven reasonable given inadequate documentation |
| Whether DCPS Guidelines should govern prevailing market rates | Guidelines should set rates; no justification for higher rates | Guidelines control prevailing market rates in this case | Accepted; DCPS Guidelines apply to rates |
| Whether specific charged hours were reasonable | All billed hours are reasonable | Some entries clerical, excessive, or vague | Denied for several entries; certain charges disallowed |
| Whether certain charges were too far in advance of the hearing | Pre-hearing work tied to hearing should be compensable | Advance work not adequately tied to a specific hearing | Denied for charges dating far before the hearing |
| Whether statutory fee cap limits recovery | Cap does not apply or is miscalculated | Recovery limited by cap | Not reached; cap argued but not applied given other determinations |
Key Cases Cited
- In re North, 59 F.3d 184 (D.C. Cir. 1995) (reasonableness of hours and detailed invoices required)
- Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir. 1995) (guidelines and market rates evidence weigh on fee awards)
- Nat'l Ass’n of Concerned Veterans v. Sec’y of Def., 675 F.2d 1319 (D.C. Cir. 1982) (establishes standards for reasonableness of hours and rates)
- Copeland v. Marshall, 641 F.2d 880 (D.C. Cir. 1980) (standard for fee shifting and invoicing detail)
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (reasonable attorney's fees framework; hours and rate analysis)
- Arrington v. United States, 473 F.3d 329 (D.C. Cir. 2006) (summarizes summary judgment standards for fee disputes)