RAWLINGS v. DISTRICT OF COLUMBIA
1:24-cv-02122
D.D.C.May 19, 2025Background
- N.W., a 12-year-old student with oppositional defiant disorder, and mother Ne'Kole Rawlings initiated an administrative claim alleging District of Columbia Public Schools (DCPS) denied N.W. a free and appropriate public education under the Individuals with Disabilities Education Act (IDEA).
- Plaintiffs alleged DCPS failed in four main ways: access to records, provision of behavioral support services per IEPs, required reevaluation, and provision of appropriate IEPs.
- The hearing officer found for Plaintiffs on three of four claims, ordering DCPS to provide educational records, 576 hours of tutoring with transportation, and 40 hours of qualified counseling.
- Plaintiffs then filed suit to recover $121,277.19 in attorneys’ fees and costs related to the successful IDEA administrative proceedings.
- DCPS did not contest eligibility for fees but argued for limitations on amounts and certain categories, contending only $29,568.98 was reasonable.
- The court awarded Plaintiffs $71,545.10 after detailed review and adjustment of hourly rates and recoverable time.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to post-settlement-offer attorneys’ fees | Plaintiffs were justified in not accepting a low settlement offer and are entitled to post-offer fees | Relief obtained was not more favorable than the pre-hearing settlement offer; post-offer fees barred | Plaintiffs were justified in rejecting the offer and may recover post-offer fees |
| Reasonableness of hours billed | Time spent on case review, meetings, and conferences was reasonable | Plaintiffs overbilled, double-billed, and included non-compensable meetings | Some time entries excluded/reduced; IEP-related/clerical time not fully compensable |
| Appropriate hourly rates | Full Fitzpatrick Matrix rates reflect complexity/market rate for IDEA cases | IDEA cases are not complex; lower (75%) matrix rate should apply | Only 75% matrix rate allowed; further reduction for less experienced attorney |
| Recovery of expert fees and paralegal work | Expert fees and educational assistant as paralegal are compensable | Insufficient proof of prevailing community rate for experts, and educational assistant not a paralegal | Expert fees not awarded; educational assistant recoverable as paralegal at proper rate |
Key Cases Cited
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (establishes the lodestar method for determining reasonable attorneys’ fees)
- Reed v. District of Columbia, 843 F.3d 517 (D.C. Cir. 2016) (prevailing market rate analysis for attorneys’ fees in IDEA cases)
- DL v. District of Columbia, 924 F.3d 585 (D.C. Cir. 2019) (IDEA litigation generally not deemed complex federal litigation)
- Nat’l Ass’n of Concerned Veterans v. Sec’y of Def., 675 F.2d 1319 (D.C. Cir. 1982) (requires showing actual billing practices to establish market rate)