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Daniels v. District of Columbia

United States District Court, District of Columbia

March 27, 2017



          DEBORAH A. ROBINSON, United States Magistrate Judge.

         Plaintiff Lashan Daniels commenced this action pursuant to the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. §§ 1400 et seq., seeking judicial review of a hearing officer's determination with respect to M.C., her minor child. Complaint (ECF No. 1) ¶ 1. Plaintiff alleges that M.C. is a student eligible for special education services, and that District of Columbia Public Schools (“DCPS”) denied M.C. a free appropriate public education (“FAPE”). Id. ¶¶ 11-15. This matter was referred to the undersigned for full case management, and the parties filed cross-motions for summary judgment in accordance with the undersigned's scheduling order. Referral (ECF No. 3); Plaintiff's Motion for Summary Judgment (ECF No. 18); Defendant's Cross Motion for Summary Judgment (ECF No. 20). The undersigned recommended that Plaintiff's motion be granted in part, and that DCPS's motion be denied. Report & Recommendation (“R&R”) (ECF No. 24) at 15. The Court (Chutkan, J.) adopted the undersigned's Report and Recommendation on September 29, 2015. Order (ECF No. 28).

         Plaintiff now seeks to recover $92, 688.92 in attorneys' fees and costs incurred in connection with the litigation. Plaintiff's Motion for Fees and Costs (“Pl.'s Mot.”) (ECF No. 30) at 1. With the consent of the parties, this case was reassigned to the undersigned for all purposes. Notice of Consent (ECF No. 33) at 1. Upon consideration of the motion; the memoranda in support thereof and in opposition thereto; the reply memorandum; the exhibits offered by the parties; and the entire record herein, the undersigned will grant Plaintiff's motion in part.


         Plaintiff asserts that she is entitled to an award of reasonable attorneys' fees because she is a “prevailing” party based on the hearing officer's determination that DCPS failed to provide a BIP and the court's decision that DCPS denied M.C. a FAPE. See Memorandum in Support of Plaintiff's Motion for Fees and Costs (“Pl.'s Mem.”) (ECF No. 30) at 4. DCPS counters that Plaintiff is a “partially” prevailing party, thus the fees must be denied or significantly reduced, because Plaintiff's motion for summary judgment was granted only in part. Defendant's Opposition to Plaintiff's Motion for Fees and Costs (“Opp'n”) (ECF No. 31) at 4. Plaintiff, in her reply, argues that she is entitled to a full recovery of attorneys' fees and costs because she prevailed on all claims that were ripe. See Plaintiff's Reply to Opposition to Motion for Fees and Costs (“Reply”) (ECF No. 32) at 1-4.

         Plaintiff argues that the requested fees are reasonable in terms of both the requested rates and the claimed hours. Pl.'s Mem. at 5, 6. In support, Plaintiff argues that the “updated” Laffey Matrix should be used to establish the prevailing market rates in the community because IDEA litigation is “complex.” Id. at 6-7.[1] DCPS argues that IDEA cases are not considered complex federal litigation, citing cases where the court granted 75% of the Laffey Matrix rates for prevailing plaintiffs. Opp'n at 5-9. In reply, Plaintiff argues that DCPS failed to produce sufficient evidence to rebut the presumption of reasonableness. See Reply at 5-7.


         In actions for attorney's fees that are brought pursuant to the IDEA, “the court, in its discretion, may award reasonable attorneys' fees as part of the costs” to the prevailing party. 20 U.S.C. § 1415(i)(3)(B)(i). In evaluating such a request, the court must first determine “whether the party seeking attorney's fees is the prevailing party, ” and if so, must then evaluate whether the requested fees are reasonable. Wood v. District of Columbia, 72 F.Supp.3d 13, 18 (D.D.C. 2014) (citing Staton v. District of Columbia, No. 13-773, 2014 WL 2700894, at *3 (D.D.C. June 11, 2014), adopted by 2014 WL 2959017 (D.D.C. July 2, 2014); Douglas v. District of Columbia, 67 F.Supp.3d 36, 40 (D.D.C. 2014)).

         As this Circuit has recently observed, “[t]he IDEA provides no further guidance for determining an appropriate fee award.” Eley v. District of Columbia, 793 F.3d 97, 100 (D.C. Cir. 2015). Thus, the common mechanism for the determination of a reasonable award is generally “the number of hours reasonably expended” multiplied by a reasonable hourly rate. Wood, 72 F.Supp.3d at 18 (citing Hensley v. Eckerhart, 461 U.S. 424, 433 (1983)).

         Prevailing Party

         To qualify as a prevailing party, the party must obtain at least “some relief” from the court. Buckhannon Bd. & Care Home, Inc. v. W.Va. Dep't of Health & Human Res., 532 U.S. 598, 603 (2001); see also Alegria v. District of Columbia, 391 F.3d 262, 264 (D.C. Cir. 2004) (applying the prevailing party analysis in the IDEA context). In determining whether the party moving for fees is a prevailing party, courts apply a three-prong test: “(1) there must be a ‘court-ordered change in the legal relationship' of the parties; (2) the judgment must be in favor of the party seeking the fees; and (3) the judicial pronouncement must be accompanied by judicial relief.” District of Columbia v. Straus, 590 F.3d 898, 901 (D.C. Cir. 2010) (citation omitted).

         Even if a party prevailed on his or her claims, the extent of the party's success is “a crucial factor in determining the amount of an award of attorney's fees.” Hensley, 461 U.S. at 438. A reduced fee award is appropriate if the relief is “limited” in comparison to the scope of the litigation as a whole. Id. However, there is no precise rule or formula for making these determinations. Id. at 436-37. In so doing, the court may “attempt to identify specific hours that should be eliminated” or “reduce the award to account for the limited success.” Id.

         Reasonable Rate

         The party requesting fees “bears the burden of establishing the reasonableness of the hourly rate sought, ” and “must submit 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.” Wood, 72 F.Supp.3d at 18-19 (internal quotation marks omitted) (citing In re North, 59 F.3d 184, 189 (D.C. Cir. 1995)).

         In this jurisdiction, the Laffey Matrix serves as the commonly accepted benchmark for the determination of prevailing market rates for attorneys' fees in complex federal court litigation. See Eley, 793 F.3d at 100. “The prevailing market rate provides merely a starting point for determining the reasonableness of a billing rate . . . . The fee applicant should also submit evidence, including affidavits, regarding her counsel's general billing practices, skill, experience and reputation.” Wood, 72 F.Supp.3d at 21 (quoting Baker v. D.C. Pub. Sch., 815 F.Supp.2d 102, 114 (D.D.C. 2011)) (citations omitted) (internal quotation marks and alterations omitted).

         The judges of this Court have adopted varying approaches to the determination of the prevailing market rate for attorneys' fees in IDEA cases. Wood, 72 F.Supp.3d at 19. “While some judges of this court have applied full Laffey rates in IDEA cases, others have applied a rate equal to three-fourths of the Laffey Matrix rate . . . where the underlying administrative proceedings did not involve particularly complex matters.” Id. (quoting Haywood v. District of Columbia, No. 12-1722, 2013 WL 5211437, at *6 (D.D.C. Aug. 23, 2013)) (citations omitted); see also Gardill v. District of Columbia, 930 F.Supp.2d 35, 42 (D.D.C. 2013) (citations omitted) (“Some courts find that the Laffey rate is presumptively reasonable . . . . Other courts treat the Laffey Matrix as providing the highest rates that will be presumed to be reasonable when a court reviews a petition for statutory attorneys' fees . . . [and] impose lower rates where the defendant shows that the proceedings for which compensation is sought were straightforward or otherwise not demanding of counsel's skills and experience.”) (internal quotation marks omitted).

         More recently, this court has cautioned that IDEA cases “take a variety of litigation paths” and cannot be dismissed as “categorically routine or simple.” Sweatt v. District of Columbia, 82 F.Supp.3d 454, 459 (D.D.C. 2015) (quoting Thomas, 908 F.Supp.2d at 243).[2] Some judges in this District “ha[ve] rejected the suggestion that IDEA administrative litigation is categorically less complex than other forms of litigation, and reaffirm[ed] that IDEA cases are sufficiently complex to allow application of the Laffey Matrix.” Id. (citations and internal quotation marks omitted). Moreover, “[s]ince an attorney's total fee award is determined by multiplying the number of hours expended by the hourly rate, reducing the Laffey rates to reflect the brevity of the case improperly accounts for the length of the proceedings twice.” Id. Thus, “[t]he complexity of the case is accounted for by the number of hours expended and should not be accounted for by a blunt reduction of rates before applying the rates to the number of hours expended.” Id.

         While the Circuit thus far has declined to decide “whether IDEA litigation is in fact sufficiently ‘complex' to use [some version of the Laffey Matrix][, ]” it has criticized the mechanical application of the proposition “that IDEA cases, as a subset of civil rights litigation, fail to qualify as ‘complex federal litigation.'” Eley, 793 F.3d at 105. In a concurring opinion, a member of the Eley panel wrote that “I would simply add that in my view, the United States Attorney's Office Laffey matrix is appropriate for IDEA cases.” Id. at 105 (Kavanaugh, J., concurring).[3]

         Reasonable ...

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