Shaw v. District of Columbia
210 F. Supp. 3d 46
| D.D.C. | 2016Background
- Plaintiff (mother of J.S.) prevailed at administrative hearings: Hearing Officer found two denials of FAPE under the IDEA. Plaintiff sought $52,556 in attorney’s fees using the USAO Laffey Matrix rates; Defendant argued fees should be 75% of Laffey, ~$38,389.40.
- Magistrate Judge Robinson recommended: plaintiff prevailing; Laffey rates appropriate; reduce claimed hours by 20% for inadequate billing judgment; reduce travel time rate by half.
- District Court reviewed objections: adopted in part and modified in part the R&R; declined to tie Laffey rates to case-by-case complexity and instead treated IDEA cases as a category warranting Laffey rates.
- Court found defendant failed to provide specific contrary market evidence to justify an automatic 25% reduction of Laffey rates to 75%.
- Court agreed there was some inadequate billing judgment in plaintiff’s time entries (vague entries, non-compensable items) but reduced total hours by 10% (not 20%); travel time awarded at one-half Laffey rate.
- Court calculated final award: total billed 105.1 hours; after applying rates, travel reduction, and 10% cut, ordered defendant to pay $46,595.25 in attorney’s fees.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are Laffey Matrix rates appropriate for IDEA fee awards? | Laffey rates apply because IDEA cases are sufficiently complex as a category. | Rates should be reduced to 75% of Laffey for administrative IDEA proceedings. | Laffey rates apply to IDEA cases as a category; defendant failed to show specific contrary market evidence. |
| May the court reduce hourly rates automatically to 75% of Laffey? | Opposed; full Laffey appropriate. | Argues precedent supports 75% reduction for IDEA matters. | Court rejects automatic 75% reduction; doing so risks double-counting brevity and lacks evidentiary support. |
| Should claimed hours be reduced for inadequate billing judgment? | Many entries were compensable (including implementation work); others were vague or non-compensable. | Magistrate’s 20% reduction appropriate to curb poor billing detail. | Court finds some inadequate billing judgment and reduces award by 10% (not 20%), explaining examples and adopting a modest holistic reduction. |
| How should travel time be compensated? | Travel time billed should be compensated, but at reduced rate. | Did not object to travel reduction recommended by magistrate. | Travel time awarded at one-half of the applicable Laffey hourly rate. |
Key Cases Cited
- Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir.) (discusses categorical approach and Laffey in IDEA context)
- Merrick v. District of Columbia, 134 F. Supp. 3d 328 (D.D.C.) (holds IDEA litigation sufficiently complex to warrant full Laffey rates)
- Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542 (U.S.) (requires reasonably specific explanation for fee determinations)
- Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir.) (burden-shifting framework in fee litigation)
- Hensley v. Eckerhart, 461 U.S. 424 (U.S.) (billing judgment and reduction principles)
- Role Models Am., Inc. v. Brownlee, 353 F.3d 962 (D.C. Cir.) (reductions for vague entries and double-billing)
- In re Meese, 907 F.2d 1192 (D.C. Cir.) (affirming 10% reduction for vague time entries)