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Gloria Santamaria et al v. District of Columbia

July 12, 2012

GLORIA SANTAMARIA ET AL., PLAINTIFFS,
v.
DISTRICT OF COLUMBIA, DEFENDANT.



The opinion of the court was delivered by: Rudolph Contreras United States District Judge

Re Document Nos.: 18, 22

MEMORANDUM OPINION

GRANTING IN PART AND DENYING IN PART THE PARTIES'CROSS-MOTIONS FOR SUMMARY JUDGMENT

I. INTRODUCTION

This matter comes before the court on the parties' cross-motions for summary judgment. The plaintiffs are the parents and next friends of several children who are protected by the Individuals with Disabilities Education Act ("IDEA"),*fn1 20 U.S.C. §§ 1400 et seq. The plaintiffs initiated this action to request an award of attorneys' fees and costs incurred while prosecuting various administrative claims under the IDEA. The defendant, the District of Columbia, disputes the reasonableness of the plaintiffs' request. The court concludes that part, but not all, of the plaintiffs' request is reasonable. Accordingly, the court grants in part and denies in part the parties' respective motions.

II. FACTUAL AND PROCEDURAL BACKGROUND

The plaintiffs are parents and next friends of a number of children enrolled in various schools within the District of Columbia Public Schools system ("DCPS"). Compl. ¶ 4. The plaintiffs initiated administrative hearings to determine whether the defendant failed to provide these children with a Free and Appropriate Public Education ("FAPE"), as the IDEA requires.

Id. Following the hearings, several children were awarded relief under the IDEA. Mem. Op. (Feb. 6, 2007) at 1--2. The plaintiffs requested reimbursement of attorneys' fees in twenty-two claims, which the defendant did not pay.*fn2 Pls.' Mot. at 1. The plaintiffs then filed this action to recover reasonable attorneys' fees and costs. See generally Compl. Initially, the parties disputed whether certain plaintiffs were "prevailing parties" under the IDEA, a question the court resolved in 2007 by concluding that most of those plaintiffs had prevailed. See Mem. Op. (Feb. 6, 2007) [Dkt. # 11]. The parties subsequently filed cross-motions for summary judgment regarding the reasonableness of the plaintiffs' fee request. Pls.' Mot. for Summ. J. ("Pls.' Mot.") [Dkt. # 18]; Def.'s Mot. for Summ. J. ("Def.'s Mot.") [Dkt. # 22]. With these motions ripe for consideration, the court now turns to the parties' arguments and to the applicable legal standards.

III. ANALYSIS

A. Legal Standard for Attorneys' Fees Under the IDEA

A district court is authorized to award "reasonable attorneys' fees" to a prevailing party under the IDEA. 20 U.S.C. § 1415(i)(3)(B). The court's award of fees is based on a two-step inquiry: the court must first determine if the party is the "prevailing" party, and second, the court must determine whether the requested fees are reasonable.*fn3 Jackson v. District of Columbia, 696 F. Supp. 2d 97, 101 (D.D.C. 2010). "The most useful starting point for determining the amount of a reasonable fee is the number of hours reasonably expended on the litigation multiplied by a reasonable hourly rate." Hensley v. Eckerhart, 461 U.S. 424, 433 (1983); see also Jackson, 696 F. Supp. 2d at 101 (applying Hensley in the IDEA context).

The plaintiff bears the burden of demonstrating that both the hourly rate and the number of hours spent on any particular task are reasonable. In re North, 59 F.3d 184, 189 (D.C. Cir. 1995). A plaintiff can do so by submitting evidence on at least three fronts: "the attorneys' billing practices; the attorneys' skill, experience, and reputation; and the prevailing market rates in the relevant community." Covington v. District of Columbia, 57 F.3d 1101, 1107 (D.C. Cir. 1995). Once the plaintiff has provided such information, a presumption arises that the number of hours billed is reasonable and the burden shifts to the defendant to rebut the plaintiff's showing. Id. at 1109--10.

B. The Court Grants in Part and Denies in Part the Parties' Cross-Motions for Summary Judgment

1. The Number of Hours Billed by the Plaintiffs' Counsel

a. Some of the Plaintiffs' Requested Fees and ...


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