Salazar v. District of Columbia, 991 F. Supp. 2d 39

Plaintiffs seek litigation costs including attorneys’ fees for 2011 and certain work from 2010-2012; remaining award to decide is $806,933.08 of total $1,283,600.86 after undisputed $476,667.78 was already awarded.
Court had previously adopted LSI-based updates to Laffey rates using CPI Legal Services Index, not Washington DC All-items CPI, and reaffirmed Salazar I/II framework.
Defendants challenge numerous fee data; the court conducts a line-by-line analysis and applies reductions where warranted.
Defendants contend Purdue v. Kenny A. affects fee methodology, but court finds Purdue does not govern this LSI-based update issue.
Settlement Order Paragraph 64 allows monitoring work by paralegals at $75/hour, below updated Laffey rates; issues arise over whether such paralegal work is compensable.
Court notes plaintiffs have filed 23 prior fee applications since Settlement Order, with defendants having paid paralegal work under Paragraph 64 in past.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether LSI-based rate updates are appropriate under Salazar I/II.	Salazar supports LSI; LSI more accurately tracks legal services costs.	Purdue requires reconsideration of fee method or undermines using LSI.	LSI-based rates are upheld; Purdue does not govern this updating method.
Whether paralegals' work at $75/hour under Paragraph 64 is properly compensable.	Paralegals perform legally substantial monitoring work; allowed under §1988.	Low rate may misallocate costs or understate true value.	Paralegal work remains compensable; rate upheld as per Settlement Order.
Whether time records for individual claims justify requested fees and reductions for overbilling.	Time records, including monitoring and related work, are reasonably tied to settlement and enforcement.	Hours for some individual claims and inter-office work were excessive or not justified.	The court applies category-specific reductions; not an across-the-board cut.
Whether expenses and “fees on fees” requests are proper under §1988 and reflect reasonable costs.	Expenses (postage, travel, PACER, copies) and fee-on-fee work are recoverable.	Some expenses should be curtailed; higher rates for copying/faxing require adjustment.	Most expenses recoverable with selective reductions in higher copy/fax rates; overall allowance sustained.

Pennsylvania v. Delaware Valley Citizens' Council for Clean Air, 478 U.S. 546 (1986) (measures necessary to enforce remedies may be recoverable)
Copeland v. Marshall, 641 F.2d 880 (D.C. Cir. 1980) (fee shifting; government fees should not be discounted in civil rights suits)
Missouri v. Jenkins, 491 U.S. 274 (1989) (attorney’s fees include paralegal work; reasonable fees encompass more than attorney time)
Richlin Sec. Serv. Co. v. Chertoff, 553 U.S. 571 (2008) (reaffirms inclusion of non-attorney work in attorney’s fees under §1988)
Salazar v. Dist. of Columbia, 750 F. Supp. 2d 70 (D.D.C. 2011) (Salazar II; supports LSI-based rate updates over DC-area all-items CPI)
Salazar v. Dist. of Columbia, 123 F. Supp. 2d 8 (D.D.C. 2000) (Salazar I; initial adoption of LSI-based methodology for fee updates)