Snead Ex Rel. C.S. v. District of Columbia
139 F. Supp. 3d 375
| D.D.C. | 2015Background
- Snead, as parent of C.S., sued the District of Columbia under IDEA to recover attorney’s fees and costs from a successful administrative proceeding.
- Plaintiff seeks fees for two attorneys, Houk ($460/hr) and Nabors ($328/hr), based on Laffey-style matrices.
- District proposes a reduced rate: ¾ of USAO Laffey rates, yielding about $50,169.51 total.
- Hearing officer’s determination found C.S. had been denied a FAPE due to the District’s actions; a Consent Order resolved the matter on February 6, 2015.
- Court analyzes prevailing market rates for IDEA administrative representation, citing Eley and related authority, and determines full Laffey rates are inappropriate for this context.
- Court awards fees at $345/hr for Houk and $191.25/hr for Nabors, with travel time at half-rate, totaling $50,169.51; plaintiff’s motion denied and defendant’s cross-motion granted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Laffey rates apply to IDEA administrative proceedings. | Snead favors full Laffey rates as prevailing community rates. | District argues IDEA proceedings are not complex federal litigation; full Laffey rates are inappropriate. | Not applicable; standard reduces to ¾ USAO Laffey rates as appropriate. |
| What rate is appropriate for Houk and Nabors in this IDEA matter? | Rates should reflect prevailing community rates for similar services in IDEA proceedings. | 75% of USAO Laffey rates best approximate prevailing rates for routine IDEA work. | Court adopts 75% of USAO Laffey (i.e., $345/hr for Houk; $191.25/hr for Nabors). |
| Is the case sufficiently complex to support higher rates under Laffey? | IDEA proceedings can be unusually complex due to LEA responsibility and administrative processes. | Case was routine, with no extensive discovery or complex legal issues. | Held that the case is not unusually complex; ¾ Laffey rate is appropriate. |
| Should travel time be compensated, and at what rate? | Travel time should be compensated at full or near-full rate. | Travel time should be paid at half the attorney’s rate. | Travel time awarded at half-rate. |
Key Cases Cited
- Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir. 1995) (burden on fee applicant to prove reasonable rates and hours)
- Eley v. District of Columbia, 793 F.3d 97 (D.C. Cir. 2015) (Laffey not presumptively applicable; need evidence rates reflect community for IDEA proceedings)
- Laffey v. Northwest Airlines, Inc., 572 F. Supp. 354 (D.D.C. 1983) (established Laffey matrix for complex federal litigation)
- Laffey (affirmation of Laffey matrix), 746 F.2d 4 (D.C. Cir. 1984) (confirmation of Laffey approach in appellate context)
- Reed v. District of Columbia, 2015 WL 5692871 (D.D.C. 2015) (courts limited reliance on full Laffey in IDEA; cited for complex-lability approach)