715 F.Supp.3d 470
E.D.N.Y.2024Background
- Robert Sampson, a medical student with ADHD and learning disabilities, enrolled at Stony Brook University's Medical School in 2015 and struggled with academics, prompting requests for testing accommodations.
- Stony Brook granted Sampson 50% extra time for school exams but Step 1 (the medical licensing exam) accommodations required approval from NBME, which repeatedly denied his requests between 2017-2019 and again in 2022.
- Stony Brook's policy required students to graduate within seven years; Sampson, awaiting accommodation for Step 1, feared expulsion as his timeframe approached expiration in 2022.
- Sampson sued Stony Brook for refusing to exempt him from the seven-year policy (alleging ADA and Rehabilitation Act violations) and filed a preliminary injunction to remain enrolled past the deadline.
- During litigation, Stony Brook voluntarily allowed Sampson to continue enrollment while he sought Step 1 relief against NBME in a separate action; parties eventually signed a stipulation allowing Sampson until August 2024 to graduate but left the issue of attorney’s fees for the court to decide.
- Sampson moved for attorney’s fees and costs, asserting he was the prevailing party due to the stipulated relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Sampson the 'prevailing party' eligible for attorney's fees? | Stipulation provided Sampson the relief sought and materially changed the parties' relationship; thus, judicial imprimatur present. | The stipulation was a voluntary, private agreement without judicial imprimatur; mere "so ordering" does not confer prevailing-party status. | Stipulation lacked judicial imprimatur; Sampson is not a prevailing party under fee-shifting statutes. |
| Should attorney’s fees be awarded despite lack of judicial imprimatur? | Even if not strictly required, equitable factors support fees since relief resulted from litigation. | Special circumstances exist: Stony Brook was not responsible for NBME's denials, supported Sampson throughout, and the dispute could have been avoided by earlier action against NBME. | Even if Sampson were prevailing party, special circumstances render fee award unjust. |
Key Cases Cited
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep't of Health & Human Res., 532 U.S. 598 (U.S. 2001) ("Judicial imprimatur" required for prevailing party status; voluntary acts do not suffice).
- CRST Van Expedited, Inc. v. EEOC, 578 U.S. 419 (U.S. 2016) (Defines "prevailing party" standard under fee-shifting statutes).
- Tex. State Teachers Ass’n v. Garland Indep. Sch. Dist., 489 U.S. 782 (U.S. 1989) (Material alteration of legal relationship required for prevailing party status).
- Roberson v. Giuliani, 346 F.3d 75 (2d Cir. 2003) (Judicial imprimatur present where court retains jurisdiction over settlement enforcement).
- Perez v. Westchester Cty. Dep’t of Corr., 587 F.3d 143 (2d Cir. 2009) (Judicial approval necessary for settlement to confer prevailing party status).
- Lefemine v. Wideman, 568 U.S. 1 (U.S. 2012) (Prevailing party should ordinarily recover attorney’s fees absent special circumstances).
- Annunziato v. The Gan, Inc., 744 F.2d 244 (2d Cir. 1984) (Fee award unjust where defendant was an innocent third party caught in plaintiffs' litigation with another party).