Reed v. District of Columbia
134 F. Supp. 3d 122
| D.D.C. | 2015Background
- Six parents/guardians (Plaintiffs) prevailed to varying degrees in IDEA administrative hearings against DC Public Schools and sought $226,625.31 in attorney fees and costs.
- Magistrate Judge Kay recommended awarding approximately $89,917.60 (about 40% of requested fees); Plaintiffs filed objections challenging rate, hour reductions, excluded activities, expense rates, and use of historical rates.
- Central legal question: what hourly rates and which billed hours are compensable under IDEA in D.C. administrative-fee cases (including whether Laffey or a reduced Laffey rate governs).
- Magistrate applied 75% of the primary USAO Laffey matrix for most matters, reduced fees for partially prevailing plaintiffs, excluded hours characterized as resolution/settlement sessions and certain temporally remote hours, and reduced copy/fax rates.
- District Judge Boasberg largely adopted the R&R but (1) affirmed using 75% of primary Laffey rates, (2) adjusted partial-prevailing reductions (reduced A.D.’s cut from 50% to 30%), (3) restored some pre-complaint and post-HOD hours for certain plaintiffs, (4) adopted $0.15/page for copying and $0.56/mile, and (5) declined to apply current (inflation-adjusted) rates.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appropriate hourly rate benchmark | IDEA work is complex; use primary or enhanced Laffey (or current rates) | Laffey not presumptive; prevailing market for IDEA is lower; 75% of primary Laffey appropriate | Court used 75% of primary USAO Laffey as prevailing market rate for IDEA in D.C. |
| Reduction for partially successful claims | Reduce or avoid across-the-board percentage cuts; many hours tied to successful claims | Reduce awards proportionally where plaintiffs only partially prevailed | Court upheld reductions for I.M. (50%) and E.J. (30%); reduced A.D.’s cut to 30% (from 50%) given relief obtained. |
| Exclusion of settlement/resolution session time | Time billed for "settlement conferences" was litigation-related and compensable | IDEA excludes time for resolution sessions; invoices insufficiently detailed to rebut statutory exclusion | Court excluded hours labeled settlement where records did not show meetings were non-statutory; upheld Magistrate’s exclusions. |
| Temporal remoteness of billed hours | Pre-complaint and some post-HOD hours were related to the proceedings and compensable | Some pre-complaint/post-HOD charges were unrelated or too remote to the IDEA claims | Court allowed most work within one year of hearing if linked to the IDEA matter; adopted some restorations (S.R., A.D.) but excluded E.J.’s unrelated pre-complaint hours. |
Key Cases Cited
- Blum v. Stenson, 465 U.S. 886 (1984) (reasonableness standard for attorney-fee awards)
- Laffey v. Northwest Airlines, Inc., 572 F. Supp. 354 (D.D.C. 1983) (origin of Laffey fee matrix for complex federal litigation)
- Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir. 2015) (burden to show rates reflect prevailing market for IDEA; Laffey not presumptive)
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (apportionment and reasonableness of hours based on success)
- Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542 (2010) (limits on enhancing lodestar for case complexity)
- Straus v. District of Columbia, 590 F.3d 898 (D.C. Cir. 2010) (three-part test for prevailing-party status under IDEA)
- McClam v. District of Columbia, 808 F. Supp. 2d 184 (D.D.C. 2011) (discussion of 75% Laffey usage in IDEA cases)