W. v. New York City Department of Education
- Ronnie Abrams
- 1:20-cv-02376
- U.S. District Court · Southern District of New York
- 2
In V.W. v. New York City Department of Education, Judge Abrams awarded CLF $2,110 in additional attorneys’ fees.
V.W. and CLF received an additional attorneys’ fee award of $2,110; the New York City Department of Education was responsible for the award.
What happened
In V.W. v. New York City Department of Education, V.W. asked for additional attorneys’ fees for work performed after June 14, 2021, under the Individual with Disabilities Education Act. The Department of Education opposed the request.
The court reviewed 15 billing entries. It rejected the first three as duplicative, approved five others at reduced hourly rates, and found that 11.6 hours spent preparing a reply brief was excessive. The court cut those hours by half.
Judge Ronnie Abrams awarded CLF $2,110 for work performed after June 14, 2021. The award was included in the court’s February 4, 2022 judgment.
The detailed version
- W. v. New York City Department of Education · No. 1:20-cv-02376
- Ronnie Abrams
- Feb. 4, 2022
Background
On January 4, 2022, the court granted V.W.’s motion for attorneys’ fees and costs under the Individual with Disabilities Education Act, with modifications. That earlier order addressed only fees requested in V.W.’s June 14, 2021 summary-judgment motion and related declarations. The court had stated that V.W. could seek additional fees for work performed after June 14, 2021, through a separate letter motion. V.W. filed that motion, and the New York City Department of Education opposed it.
Billing entries
According to a reply declaration from Andrew Cuddy, CLF added 15 entries to its federal billing statement for work performed after June 14, 2021, and requested approximately $8,000 for that work.
The court found that the first three entries appeared duplicative of entries already included in the earlier fee request and discounted them. It found entries four, five, six, fourteen, and fifteen reasonable because they documented a modest number of hours spent on correspondence, administrative work, or final review by senior partners. The court allowed those entries at the reduced hourly rates set in its prior order: $400 per hour for Andrew Cuddy, $300 for Justin Coretti, $125 for Shobna Cuddy, and $100 for less experienced legal assistants. Those entries produced a total of $370.
Entries seven through thirteen covered 11.6 hours that Justin Coretti spent researching case law, drafting V.W.’s reply in support of her summary-judgment motion and related documents, and reviewing the Department of Education’s opposition. The court found those hours excessive because the reply was brief and similar to the opening brief. It reduced Coretti’s hours by 50%, resulting in 5.8 billable hours at his adjusted rate of $300 per hour, or $1,740.
Ruling
The court awarded CLF a total of $2,110 in attorneys’ fees for work performed after June 14, 2021. The award was reflected in the court’s February 4, 2022 judgment. This order addressed an ancillary fee request rather than the underlying disability-education dispute.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.