McNeil v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedSeptember 28, 2018
DocketCivil Action No. 2014-0886
StatusPublished

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Bluebook
McNeil v. District of Columbia, (D.D.C. 2018).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

_________________________________________ ) JUDIE MCNEIL, et al., ) ) Plaintiffs, ) ) v. ) Case No. 14-cv-00886 (APM) ) DISTRICT OF COLUMBIA, ) ) Defendant. ) _________________________________________ )

MEMORANDUM OPINION AND ORDER

I. INTRODUCTION

Plaintiff Judie McNeil and her son, J.M., now an adult and co-plaintiff, seek to collect

$198,653.43 in attorneys’ fees and other costs associated with a successful action under the

Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq., against

Defendant District of Columbia. 1 Defendant does not contest Plaintiffs’ status as a prevailing

party under the IDEA, but does assert that the proposed hourly rates for Plaintiffs’ counsel are not

supported by adequate evidence and therefore are unreasonable. Moreover, Defendant asserts that

attorneys’ fees incurred before May 2013 are too attenuated to be compensated and that Plaintiffs

cannot recover costs expended for experts. Defendant asks the court to award no more than

$110,311.54.

1 The court arrived at this figure by adding together Plaintiffs initial request, Pl.’s Mot. for Fees & Costs, ECF No. 30, at 1, and Plaintiffs request for costs and fees documented in their reply brief, Pl.’s Reply Regarding Fees & Costs, ECF No. 33, at 26. After considering the parties’ submissions and the relevant law, the court grants in part and

denies in part Plaintiffs’ Motion for Attorney Fees. 2 The court awards attorneys’ fees and costs to

Plaintiffs calculated at an hourly rate of 75% of the United States Attorney’s Office Matrix, in the

total amount of $140,238.97.

II. BACKGROUND

The court described the factual and procedural background of this case in its previous

opinion, which resolved the parties’ cross-motions for summary judgment and remanded for

further administrative proceedings. See generally McNeil v. District of Columbia, 217 F. Supp.

3d 107 (D.D.C. 2016). Thus, the court need not repeat those details here. On remand, the Hearing

Officer made several additional factual findings and determinations in Plaintiffs’ favor and held

that J.M. was entitled to compensatory education. Pl.’s Mot. for Fees & Costs, ECF No. 30

[hereinafter Pl.’s Mot.], at 3; Def.’s Mem. in Opp’n to Pl.’s Mot. for Fees & Costs, ECF No. 31

[hereinafter Def.’s Opp’n], at 3; see also Pl.’s Mot., Ex. 1, ECF No. 30-1, at 10–11. Thus, Plaintiffs

succeeded in securing the relief they sought for J.M. See generally Compl., ECF No. 1, at 3.

III. LEGAL STANDARD

The IDEA provides “a fee-shifting provision entitling a prevailing party . . . to reasonable

attorneys’ fees.” Price v. District of Columbia, 792 F.3d 112, 113 (D.C. Cir. 2015) (internal

quotation marks omitted). A “court, in its discretion, may award reasonable attorneys’ fees as part

of the costs . . . to a prevailing party who is the parent of a child with a disability.” 20 U.S.C.

§ 1415(i)(3)(B)(i)(I). An IDEA fee award “shall be based on rates prevailing in the community in

which the action or proceeding arose for the kind and quality of services furnished.” Id.

2 On September 26, 2018, Plaintiffs sought to file a supplemental memorandum and evidence in support of their fees petition. See Pls.’ Mot. for Leave to File Supp. Mem. in Support of Pls.’ Motion for Fees and Costs. For the reasons set forth in the accompanying Order, the court denies that motion and has not considered Plaintiffs’ supplemental filing.

2 § 1415(i)(3)(C). If the court finds, however, “that ‘the amount of the attorneys’ fees otherwise

authorized to be awarded unreasonably exceeds the hourly rate prevailing in the community for

similar services by attorneys of reasonably comparable skill, reputation, and experience,’ it ‘shall

reduce . . . the amount of the attorneys’ fees awarded.’” Eley v. District of Columbia, 793 F.3d 97,

99 (D.C. Cir. 2015) (alteration in original) (emphasis omitted) (quoting 20 U.S.C.

§ 1415(i)(3)(F)(ii)).

Because the IDEA “provides no further guidance for determining an appropriate fee

award,” id. at 100, the D.C. Circuit applies a “two-part framework” to determine whether an award

of attorneys’ fees is “reasonable” under the statute’s fee-shifting provision, see Reed v. District of

Columbia, 843 F.3d 517, 520 (D.C. Cir. 2016). This framework takes into account “(1) the

‘number of hours reasonably expended in litigation’; and (2) the ‘reasonable hourly rate’ for the

services provided.” Reed, 843 F.3d at 520 (quoting Eley, 793 F.3d at 100).

The burden of establishing entitlement to a fee award under the IDEA rests with the fee

applicant. See id. The applicant must establish that she qualifies as a prevailing party, document

the appropriate hours spent by counsel, and justify the reasonableness of the rate requested. See

id. at 520–21; cf. Covington v. District of Columbia, 57 F.3d 1101, 1107 (D.C. Cir. 1995)

(explaining burden-shifting in the context of a fees petition under 42 U.S.C. § 1988). Once the

applicant has shown that the claimed rate and hours are reasonable, the resulting sum is presumed

to be a reasonable fee. See Covington, 57 F.3d at 1109. At that point, the defendant can challenge

the request for attorneys’ fees, but it must do so with “specific contrary evidence tending to show

that a lower rate would be appropriate.” Flood v. District of Columbia, 172 F. Supp. 3d 197, 203

(D.D.C. 2016) (quoting Covington, 57 F.3d at 1109–10).

3 The IDEA also allows “[p]arties who prevail at the administrative level [to] recover fees-

on-fees . . . for time reasonably devoted to obtaining attorney’s fees.” McNeil v. District of

Columbia, 233 F. Supp. 3d 150, 153 (D.D.C. 2017) (alterations in original) (quoting Kaseman v.

District of Columbia, 444 F.3d 637, 640 (D.C. Cir. 2006)); see also Jones v. District of Columbia,

153 F. Supp. 3d 114, 118 (D.D.C. 2015) (“The availability of reasonable attorneys’ fees applies to

fees incurred in IDEA litigation both before administrative agencies and in federal court, as well

as to fees incurred to vindicate a plaintiff’s right to fees.”). In a previous decision, this court

outlined the relevant legal standards governing motions for attorneys’ fees brought pursuant to the

IDEA’s fee-shifting provision, see James v. District of Columbia, 302 F. Supp. 3d 213, 216–218

(D.D.C. 2018), and the court adopts and applies those standards here.

IV. DISCUSSION

A. Reasonableness of Rates

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802 F. Supp. 2d 56 (District of Columbia, 2011)
Dicks v. District of Columbia
109 F. Supp. 3d 126 (District of Columbia, 2015)
Price Ex Rel. J.P. v. District of Columbia
792 F.3d 112 (D.C. Circuit, 2015)
Eley v. District of Columbia
793 F.3d 97 (D.C. Circuit, 2015)
Flood Ex Rel. T.F. v. District of Columbia
172 F. Supp. 3d 197 (District of Columbia, 2016)
McNeil v. District of Columbia
217 F. Supp. 3d 107 (District of Columbia, 2016)
Reed v. District of Columbia
843 F.3d 517 (D.C. Circuit, 2016)
McNeil v. District of Columbia
233 F. Supp. 3d 150 (District of Columbia, 2017)
N.W. v. District of Columbia
253 F. Supp. 3d 5 (District of Columbia, 2017)
Covington v. District of Columbia
57 F.3d 1101 (D.C. Circuit, 1995)
Jones v. District of Columbia
153 F. Supp. 3d 114 (District of Columbia, 2015)
Daniel ex rel. M.H. v. District of Columbia
174 F. Supp. 3d 532 (District of Columbia, 2016)
Lee v. Dist. of Columbia
298 F. Supp. 3d 4 (D.C. Circuit, 2018)
James v. Dist. of Columbia
302 F. Supp. 3d 213 (D.C. Circuit, 2018)
Lee v. Dist. of Columbia
303 F. Supp. 3d 57 (D.C. Circuit, 2018)

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