## Facts

- A Chicago Public Schools student with disabilities prevailed in an IDEA administrative due-process hearing against the school district.
- After the administrative victory, the student’s parent filed a federal action seeking attorneys’ fees and costs under 20 U.S.C. § 1415(i)(3).
- Plaintiff requested about $95,000 in fees based on counsel time records and claimed market rates for IDEA litigation in Chicago.
- The school district did not dispute prevailing-party status but contested the amount, arguing many entries were excessive, duplicative, clerical, or tied to unsuccessful or unrelated work and that rates should be lower; it urged an award around $53,500.
- The parties filed cross-motions for summary judgment limited to the proper amount of fees and costs.

## Issues

1. Whether the hours billed were reasonably expended, or should be reduced as excessive, redundant, unnecessary, or clerical.
2. Whether the requested hourly rates reflected prevailing market rates for similar IDEA work in the relevant community.
3. Whether, and how, the fee should be reduced for partial or limited success and for work on unsuccessful or unrelated claims.
4. Which categories of work were compensable legal services under § 1415(i)(3) versus non-compensable administrative tasks.

## Decision

- The court held plaintiff was a prevailing party eligible for a discretionary fee award under 20 U.S.C. § 1415(i)(3)(B).
- The court applied the lodestar method (reasonable hours × reasonable rate), then considered adjustment based on results obtained.
- The court reduced billed time for entries it found excessive, duplicative, or clerical, including instances where multiple attorneys billed for tasks reasonably performed by one.
- The court evaluated evidence of market rates and adjusted rates where not adequately supported or not justified by experience and task type.
- The court considered the degree of success and reduced fees to account for limited success or discrete unsuccessful matters where appropriate.
- The court granted each side’s motion in part and denied each in part, awarding a reduced amount below the request but above the district’s proposed figure.

## Legal Principles

- Under IDEA, a court may award reasonable attorneys’ fees to a parent who is the prevailing party in an administrative proceeding. 20 U.S.C. § 1415(i)(3)(B).
- Reasonableness is generally determined by the lodestar method, excluding hours not reasonably expended.
- Duplicative attorney staffing and purely clerical or administrative work are not compensable at attorney rates and may be excluded or reduced.
- A reasonable hourly rate is the prevailing market rate for similar services by lawyers of comparable skill and experience in the relevant community.
- Fee awards may be reduced for limited success; time spent on distinct unsuccessful claims should be excluded, while work tied to a common core of facts may remain compensable subject to results-based reduction.

## Conclusion

The court awarded IDEA attorneys’ fees to the prevailing student but reduced the lodestar to reflect unreasonable time entries, non-compensable clerical work, unsupported rates, and the extent of success achieved in the administrative proceeding.


Ryan M. v. Bd. of Educ. of the City of Chi., Dist. 299, 731 F. Supp. 2d 776 (N.D. Ill. 2010)