Virginia Elizondo v. Spring Branch Independent School District, et al.

CourtDistrict Court, S.D. Texas
DecidedOctober 27, 2025
Docket4:21-cv-01997
StatusUnknown

This text of Virginia Elizondo v. Spring Branch Independent School District, et al. (Virginia Elizondo v. Spring Branch Independent School District, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Virginia Elizondo v. Spring Branch Independent School District, et al., (S.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT October 27, 2025 FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Nathan Ochsner, Clerk VIRGINIA ELIZONDO, § § Plaintiff, § § v. § CIVIL ACTION NO. H-21-1997 § SPRING BRANCH INDEPENDENT § SCHOOL DISTRICT, et al., § § Defendants. § MEMORANDUM OPINION AND ORDER Pending before the court is Plaintiff’s Motion for Attorneys Fees and Costs (Docket Entry No. 131), seeking over $1.4 million through trial, pursuant to Federal Rule of Civil Procedure 54(d), 28 U.S.C. § 1920, and the fee-shifting provision of the Voting Rights Act (“VRA”), 52 U.S.C. § 10310(e).1 Also pending are Defendants’ Objections to Plaintiff’s Motion for Attorney’s Fees and Costs (“Defendants’ Objections”) (Docket Entry No. 147), urging the court to deny Plaintiff’s motion or, alternatively, to exclude Dr. Tijerina’s expert witness fees and costs, and Plaintiff’s Reply to Defendants’ Objections to Plaintiff’s Motion for Attorney’s Fees and Costs (“Plaintiff’s Reply”) (Docket Entry No. 149). For the reasons stated below, Plaintiff’s Motion for Attorneys Fees and Costs will be granted. 1Plaintiff’s Motion for Attorneys Fees and Costs, Docket Entry No. 131, p. 16. All page numbers reference the pagination imprinted at the top of the page by the court’s Electronic Case Filing system. 1 I. Background This is an action brought under § 2 of the VRA, 52 U.S.C. § 10301, et seq., challenging the legality of the at-large method for electing members of the Spring Branch Independent School District (“SBISD”) Board of Trustees. Following a five-day bench trial in September of 2024 the court issued a Memorandum Opinion and Order on April 28, 2025 (Docket Entry No. 122), stating findings of fact and conclusions of law, declaring that “SBISD’s current at-large system of electing school board trustees violates the VRA,”2 and finding that Plaintiff is the prevailing party . . . entitled to court costs and to an award of attorney’s fees under Fed. R. Civ. P. 54(d). The Court will defer deciding the amount of attorney’s fees to which Plaintiff is entitled until Plaintiff seeks such relief under Fed. R. Civ. P. 54(d).3 On August 6, 2025, the court entered a Memorandum Opinion and Order (Docket Entry No. 129) denying SBISD’s proposed 5-2 hybrid remedial plan, and granting Plaintiff’s proposed 7-0 single-member remedial plan. The court also entered Final Judgment (Docket Entry No. 130), ordering Defendants “to implement the seven single member district plan proposed in Plaintiff’s Objections to Defendants’ Proposed Remedial Plan and Plaintiff’s Alternative Remedial Plan (Docket Entry No. 127) in time for SBISD’s next regularly scheduled election in May of 2026.” 2Memorandum Opinion and Order, Docket Entry No. 122, p. 113. 3Id. at 112 ¶ 55. 2 On August 15, 2025, Plaintiff filed her Motion for Attorney’s Fees and Costs seeking over $ 1.4 million through trial.4 On August 25, 2025, Defendants filed a Notice of Appeal (Docket Entry No. 136), Defendants’ Motion to Defer Consideration of Plaintiff’s Motion for Attorneys’ Fees and Costs Pending Appeal (“Defendants’ Motion to Defer”) (Docket Entry No. 132), and Defendants’ Motion to Stay Final Judgment Pending Appeal (“Defendants’ Motion to Stay”)(Docket Entry No. 135). On September 17, 2025, the court entered a Memorandum Opinion and Order (Docket Entry No. 143) granting Defendants’ Motion to Stay, Denying Defendants’ Motion to Defer, and ordering Defendants to respond to Plaintiff’s Motion for Attorneys Fees and Costs. On October 1, 2025, Defendants filed their response, and on October 8, 2025, Plaintiff filed her reply.

II. Standard of Review Plaintiff has timely moved under Federal Rule of Civil Procedure 54(d) for an award of reasonable attorney’s fees and taxable costs which, pursuant to the VRA’s fee-shifting provision, includes reasonable litigation expenses in addition to the categories of costs authorized by 28 U.S.C. § 1920. Rule 54(d)(1) states that “[u]nless a federal statute, these rules, or a court order provides otherwise, costs — other than attorney’s fees —

4Plaintiff’s Motion for Attorneys Fees and Costs, Docket Entry No. 131, p. 16. 3 should be allowed to the prevailing party.” Although taxation of costs under Rule 54(d)(1) is a matter within the court’s discretion, Taniguchi v. Kan Pacific Saipan, Ltd., 132 S. Ct. 1997, 2001 (2012), courts “may neither deny nor reduce a prevailing party’s request for cost[s] without first articulating some good reason for doing so.” Pacheco v. Mineta, 448 F.3d 783, 794 (5th Cir.), cert. denied sub nom., Pacheco v. Cino, 127 S. Ct. 299 (2006). Unless expressly authorized by statute, courts may only tax as costs the expenses listed in 28 U.S.C. § 1920: (1) Fees of the clerk and marshal; (2) Fees for printed or electronically recorded transcripts necessarily obtained for use in the case; (3) Fees and disbursements for printing and witnesses; (4) Fees for exemplification and the costs of making copies of any materials where the copies are necessarily obtained for use in the case; (5) Docket fees under [§] 1923 of this title; and (6) Compensation of court appointed experts, compensation of interpreters, and salaries, fees, expenses, and costs of special interpretation services. 28 U.S.C. § 1920. The VRA’s fee-shifting provision expands the taxable costs available to prevailing plaintiffs. That provision states: In any action or proceeding to enforce the voting guarantees of the fourteenth or fifteenth amendment, the court, in its discretion, may allow the prevailing party . . . a reasonable attorney’s fee, reasonable expert fees, and other reasonable litigation expenses as part of the costs. 4 52 U.S.C. § 10310(e) (formerly 42 U.S.C. § 1973l1(e)). The VRA’s fee-shifting provision is interpreted under the same legal standard as the similar provision in 42 U.S.C. §$ 1988. See Craig v. Gregg County, Texas, 988 F.2d 18, 20 (5th Cir. 1993) (“Because the phrase ‘prevailing party’ connotes the same general meaning under § [10310(e)] and 42 U.S.C. §$ 1988, cases under both Acts apply the same principles when determining plaintiff’s entitlement to attorneys’ fees.”). Thus, a prevailing plaintiff in a VRA case “should ordinarily recover an attorney’s fee unless’ special circumstances would render such an award unjust.” Lefemine v. Wideman, 133 S. Ct. 9, 11 (2012) (per curiam) (quoting Hensley v. Eckerhart, 103 S. Ct. 1933, 1937 (1983) (quoting Newman v. Piggie Park Enterprises, Inc., 88 S. Ct.

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Bluebook (online)
Virginia Elizondo v. Spring Branch Independent School District, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/virginia-elizondo-v-spring-branch-independent-school-district-et-al-txsd-2025.