Irving v. D.C. Public Schools
2011 U.S. Dist. LEXIS 112275
| D.D.C. | 2011Background
- Plaintiff Virginia Hayes, as grandmother and legal guardian, pursued IDEA fees for her minor grandchild in DCPS proceedings.
- Administrative due-process complaint against DCPS and DC alleged failure to provide FAPE; merits hearing held January 2009 resulting in a favorable Hearing Officer Determination for plaintiff.
- Plaintiff’s counsel billed $4,101.15 in attorney’s fees; defendants reimbursed $923.75, leaving a差 balance.
- Plaintiff filed this action in August 2009 to recover the remaining $4,101.15; case removed to this court and amended in July 2010.
- Court analyzes whether fee request is reasonable under IDEA, controlling standards, and prevailing-party status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prevailing party entitlement | Pl. prevailed on merits; entitled to reasonable fees. | Defendants acknowledge prevailing-party status but dispute fee reasonableness. | Plaintiff is prevailing party; fee-shifting allowed. |
| Detail of time records and task attribution | User summary suffices; detailed per-attorney task not required by DCPS Guidelines. | Vague petition prevents assessment of rates and hours; need identification of specific attorneys. | Incomplete attribution necessitates reductions but not total denial; some hours reducible. |
| Remoteness of pre-merits time | Pre-merits activities directly relate to and support merits outcome. | Hours incurred eight months before merits hearing were too remote. | Hours tied to underlying proceedings; pre-merits work deemed reasonable. |
| Appropriate hourly rates (Laffey Matrix vs DCPS schedule) | Laffey Matrix rates (adjusted or standard) reflect prevailing market rates; DCPS schedule is outdated. | DCPS fee schedule should apply; IDEA cases are not same as complex federal litigation. | Laffey Matrix applicable; DCPS schedule rejected; adjusted vs standard rates discussed. |
| Attorneys' qualifications and rate reasonableness | Declarations show counsel’s qualifications justify requested rates. | Need more evidence of qualifications and market rates; some non-attorneys billed at attorney rates. | Presumption of reasonableness established; rates determined primarily by Laffey Matrix with adjustments. |
Key Cases Cited
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598 (Supreme Court 2001) (prevailing-party status requires some relief from court)
- Hensley v. Eckerhart, 461 U.S. 424 (Supreme Court 1983) (overtime hours and reasonable-fee calculation guidance)
- Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir. 1995) (evidence of prevailing market rates; rebuttal burden on opponents)
- National Association of Concerned Veterans v. Sec’y of Def., 675 F.2d 1319 (D.C. Cir. 1982) (detailed invoicing supports independent review of hours)
- Jordan v. Dep’t of Justice, 691 F.2d 514 (D.C. Cir. 1982) (extreme deficiencies can justify denial, but partial reduction allowed)