DEBORAH A. ROBINSON, United States Magistrate Judge.
Plaintiff Shamea Briggs brings this action to recover attorneys' fees and costs that she incurred in connection with administrative proceedings conducted pursuant to the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. § 1400, et seq. Complaint (Document No. 1). On April
Plaintiff Shamea Briggs is the parent of J.K., a minor student residing in the District of Columbia who is eligible to receive special education and related services. Complaint (Document No. 1) ¶¶ 2,4. On January 24, 2013, an administrative due process hearing under the IDEA was held with regard to J.K. Id. ¶ 4. That same day, the Hearing Officer issued a decision finding that Plaintiff was the prevailing party. Id. On May 22, 2014, Plaintiff submitted a fee petition for $28,773.12, which became the subject of the previous fee litigation in this matter. Id. ¶ 5.
In an order adopting the Report and Recommendation issued by the Magistrate Judge to whom the matter had been referred, the assigned United States District Judge to whom this matter was then assigned awarded Plaintiff $20,934.78 in legal fees and costs. See Order (Document No. 19). In so doing, the Court the determined that based on the circumstances and complexity of the matter, Plaintiff was entitled to an award reflecting an hourly rate at three-quarters of her counsel's applicable hourly rate based on the Laffey matrix.
Plaintiff submits that she was the prevailing party in this action and is, therefore, entitled to reasonable attorneys' fees and costs as provided by the applicable authorities. See Plaintiff's Points and Authorities in Support of Plaintiff's Motion for an Award of Attorney Fees and Costs ("Plaintiff's Memorandum") (Document No. 20-1) at 2. Accordingly, as a result of the aforementioned fee-collection litigation, Plaintiff seeks a total of $13,786.59, which reflects $13,313 in attorneys' fees at a rate of $520 per hour. Plaintiff's Memorandum (Document No. 20-1) at 2; see also Plaintiff's Invoice (Document No. 20-4); see also Plaintiff's Reply to Defendant's Opposition to Plaintiff's Motion for Attorney Fees (Plaintiff's Reply") (Document No. 22) at 4.
Through written submissions, and on the record at the May 28, 2015 hearing, Defendant urges the court to use its discretion to deny Plaintiff any additional award of attorney's fees.
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). "Parties who prevail at the administrative level can also recover fees-on-fees, as our general rule is that the court may award additional fees for `time reasonably devoted to obtaining attorney's fees.'" Kaseman v. District of Columbia, 444 F.3d 637, 640 (D.C.Cir.2006) (quoting Envtl. Def. Fund v. EPA, 672 F.2d 42, 62 (D.C.Cir.1982)). 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; Douglas v. District of Columbia, 67 F.Supp.3d 36, 40 (D.D.C.2014)).
As the Circuit 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, F. Supp. 3d at 18 (citing Hensley v. Eckerhart, 461 U.S. 424, 433, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983)). The party requesting fees bears the burden of demonstrating the reasonableness of the hours expended, and "may satisfy this burden by submitting an invoice that is sufficiently detailed to permit the District Court to make an independent determination whether or not the hours claimed are justified." Id. (citing Hensley, 461 U.S. at 433, 103 S.Ct. 1933). The party requesting fees "also bears the burden of establishing the reasonableness of the hourly rate sought," and in doing so, "must
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. District of Columbia Pub. Sch., 815 F.Supp.2d 102, 114 (D.D.C.2011)) (citations omitted) (internal quotation marks and alterations omitted).
With regard to fee-collection or fees-on-fees litigation in IDEA matters, it is well settled that the straightforward nature of the proceedings warrants an award at one-half of an attorney's applicable Laffey rate. See, e.g., Briggs v. District of Columbia, 102 F.Supp.3d 164, 169 (D.D.C.2015); Turley v. District of Columbia, No. 14-0004, 2015 WL 7292752, at *5 (D.D.C. Oct. 20, 2015); Staton v. District of Columbia, No. 13-cv-1966, 2015 WL 5728884, at *5 (D.D.C. Sept. 30, 2015); Means v. District of Columbia, 999 F.Supp.2d 128, 136 (D.D.C.2013); Garvin v. District of Columbia, 910 F.Supp.2d 135, 140 (D.D.C.2012); Wright v. District of Columbia, 883 F.Supp.2d 132, 135 (D.D.C.2012); Collins v. District of Columbia, No. 15-00136, 146 F.Supp.3d 32, 44-46, 2015 WL 7720464, at *10 (D.D.C. Nov. 30, 2015).
In addition, when "a plaintiff has achieved only partial or limited success, the product of hours reasonably expended on the litigation as a whole times a reasonable hourly rate may be an excessive amount." Hensley, 461 U.S. at 436, 103 S.Ct. 1933. Therefore, a "success based" reduction in an award may be warranted given certain circumstances. See Briggs, 102 F.Supp.3d at 171 (further reducing an award to reflect the fact that counsel was only awarded three-quarters of their applicable Laffey rate with regard to the initial fees litigation).
The court finds that an award of attorneys' fees for Plaintiff's counsel at the full Laffey rate is not warranted under these circumstances. Plaintiff was, in fact, the prevailing party with regard to the previous fees litigation, and is, therefore, entitled to reasonable attorneys' fees given such circumstances. However, in accordance with the established precedent of this jurisdiction, Plaintiff's award of attorneys' fees in this action should be awarded at one-half of her attorney's applicable Laffey rate, given the straightforward and routine nature of the fees on fees litigation.
The court finds that the number of hours billed by Plaintiff's attorney is reasonable. As previously mentioned, only 4.5 hours are in dispute. Plaintiff is entitled to reimbursement for the time spent by her attorney preparing her respective submission to this court. See Jones v. District of Columbia, No. 15-155, 153 F.Supp.3d 114, 121-22, 2015 WL 9907797, at *5 (D.D.C. Oct. 29, 2015 (rejecting the argument that preparation of a motion in fees-on-fees litigation is too attenuated from the administrative process). Therefore, Plaintiff is entitled to reimbursement for 25.90 hours. See Plaintiff's Invoice (Document No. 20-4) at 3; see also Plaintiff's Reply (Document No. 22) at 4.
Accordingly, this court awards Plaintiff $5,050.50 in attorneys' fees and $473.59 in costs.
For all the foregoing reasons, it is, this 23rd day of March, 2016,