Wood v. District of Columbia
2014 U.S. Dist. LEXIS 152151
| D.D.C. | 2014Background
- Plaintiffs are Tarcha Wood and D.W., a DC resident child eligible for special education, seeking IDEA attorneys’ fees from DCPS.
- Wood filed an administrative due process complaint on Oct. 16, 2012 alleging DCPS denied FAPE in multiple ways, including placement, IEP process, evaluations, and related services.
- Pre-hearing conferences were held Nov. 20–27, 2012; the Hearing Officer (HOD) certified some claims but Wood later withdrew compensatory education claims and amended others.
- The HOD found DCPS denied FAPE by failing to comprehensively evaluate D.W. in May 2012 and by failing to provide certain assessments and services; DCPS prevailed on other pre-specified issues.
- Plaintiffs seek $59,885.25 in fees and costs; the court must determine prevailing party status, reasonableness of hours and rates, and adjusts fees when only partial success is achieved.
- The court awards three-fourths of the Laffey rates due to routine complexity and partial success, totaling $44,953.87 including costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonableness of hourly rates for counsel | Wood argues full Laffey rates are warranted based on experience and complexity. | DCPS argues lower rates (3/4 Laffey or lower) are appropriate given routine IDEA issues. | Rates reduced to 3/4 Laffey; $326.25/hr for Houck and Kotler. |
| Whether plaintiffs were prevailing parties and to what extent | Plaintiffs prevailed on most issues and seek fees as prevailing party. | Defendant contends partial success limits fee entitlement. | Plaintiffs prevailed on most issues but not all; fee award reflects partial success. |
| Complexity of the administrative proceedings justifies full Laffey rates | Bullying/harassment theory and extensive briefing warranted full rates. | Proceedings were routine IDEA disputes; no unique complexity. | Proceedings not sufficiently complex for full Laffey; 3/4 Laffey rates apply. |
| Applicability of SOCM and Hensley framework to determine fee adjustment | SOCM/Hensley support awarding reasonable hours at reasonable rates. | Contends the framework supports lower award given partial success. | Adopts SOCM/Hensley framework; adjusts downward for partial success. |
Key Cases Cited
- Gardill v. Dist. of Columbia, 930 F. Supp. 2d 35 (D.D.C. 2013) (complexity factors; some cases permit reduced LI rates when not highly complex)
- Hensley v. Eckerhart, 461 U.S. 424 () (adjust fee based on results obtained; partial success reductions)
- Laffey v. Northwest Airlines, Inc., 572 F. Supp. 354 (D.D.C. 1983) (foundation for prevailing market rates in complex matters)
- Jackson v. Dist. of Columbia, 696 F. Supp. 2d 97 (D.D.C. 2010) (recognizes use of Laffey rates in IDEA fee awards)