YOUNG v. DISTRICT OF COLUMBIA
1:11-cv-01041
D.D.C.Sep 28, 2012Background
- Plaintiffs seek IDEA attorney fees and a declaration that the DCPS Fee Guidelines are unlawful.
- Hearing occurred after several prehearing conferences; the administrative decision favored plaintiffs.
- Plaintiffs claimed 68.75 hours for Hecht and 1.5 hours for Neloms; DCPS reimbursed at DCPS rates.
- Magistrate Judge recommended no declaratory relief and $5.55 costs, and discounted fees by 25%.
- Court adopts denial of declaratory relief and costs, but rejects the 25% rate discount and full hour reduction.
- Court awards the requested rates ($270/hr Hecht, $330/hr Neloms) for nearly all hours, minus 2.17 Hecht hours.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicable hourly rates for fees | Young—Laffey rates should apply in full. | DCPS guidelines should control rates. | Laffey rates apply; 25% discount rejected. |
| Whether hours for settlement conference are compensable | Hours for settlement activities are recoverable. | Settlement prep time should be excluded. | Exclude 2.17 hours; remaining hours recoverable. |
| Declaratory relief regarding DCPS Fee Guidelines | Guidelines unlawful; should be declared invalid. | IDEA provides no vehicle to review guidelines. | Declatory relief denied. |
| Costs award | Costs in line with invoices. | Costs are within court-approved amounts. | Costs awarded: $5.55. |
Key Cases Cited
- Covington v. District of Columbia, 57 F.3d 1101 (D.C. Cir. 1995) (Laffey rates and fee-shifting framework relevant)
- Jackson v. District of Columbia, 696 F. Supp. 2d 97 (D.D.C. 2010) (applies Laffey rates in IDEA fee awards)
- Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (reasonableness of fees based on hours and rates)
- In re North, 59 F.3d 184 (D.C. Cir. 1995) (three-fronts test for reasonable hourly rates)