Huntley v. District of Columbia ( 2012 )


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  •                        UNITED STATES DISTRICT COURT
    FOR THE DISTRICT OF COLUMBIA
    ____________________________________
    YVONNE HUNTLEY,                      )
    Plaintiff,         )
    v.                           )  Civil Action No. 11-163 (AK)
    DISTRICT OF COLUMBIA,               )
    Defendant.         )
    ____________________________________)
    MEMORANDUM OPINION
    This matter is pending before this Court on Plaintiffs’ Motion for [summary judgment on
    the issue of] Fees and Costs (“Fee Motion”) and Memorandum in support thereof
    (“Memorandum”) [10]; Defendant’s opposition to the Motion (“Opposition”) [11]; and
    Plaintiff’s reply to the Opposition (“Reply”) [12].1 Plaintiff Yvonne Huntley (“Plaintiff’) has
    requested $1,412.35 in legal fees and costs, a portion of which is contested by Defendant District
    of Columbia (“Defendant” or “the District”) on grounds that the documentation supporting such
    claim is inadequate; the hourly rate charged by Plaintiff’s counsel is excessive and some of
    counsel’s billing entries are “remote” in time. (Opposition, Exh. 1 [Defendant’s chart of
    proposed allowable fees and reasons for fee reductions].)2
    I. BACKGROUND
    Plaintiff is the guardian of a minor child who prevailed in an administrative action
    brought pursuant to the Individuals with Disabilities Education Act and the Individuals with
    Disabilities in Education Improvement Act ( collectively “IDEA”), 
    20 U.S.C. § 1400
     et seq.
    Pursuant to 
    20 U.S.C. §1415
    (i)(3)(B), a court may award attorney’s fees to a parent who prevails
    1
    This same Fee Motion is filed in multiple cases involving claims for attorneys’ fees and
    costs; the Plaintiff in this action is Yvonne Huntley.
    2
    Defendant’s chart entries for the three claims by this Plaintiff [the Superior Court
    captions, District Court captions, and amounts claimed] are erroneously recorded.
    in an IDEA proceeding. Prior to filing this civil action, the Plaintiff participated in a February
    12, 2008 due process hearing wherein the Hearing Officer determined that:
    DCPS violated the terms of the Consent Decree by refusing to honor the letter from
    Petitioner’s counsel requesting a compensatory education meeting, and by insisting that
    such a meeting could be requested only by means of a selection card, because the
    Consent Decree does not require the use of any particular method for electing a
    compensatory education meeting.
    (February 22, 2008 Impartial Due Process Hearing Officer’s Decision (“HOD”) at 5, attached to
    Notice of Removal [1] (emphasis in original).) The Hearing Officer inter alia ordered DCPS to
    “convene an IEP/MDT meeting to discuss and determine the form and amount of compensatory
    education due Student. . . .” (Id.)
    The District does not contest Plaintiff’s prevailing party status in this case but the District
    does note an objection to Plaintiff’s “inadequate documentation” in the chart attached to its
    Opposition as Exhibit 1. The District proffers no explanation for this objection other than its
    claim that the HOD in this case “appears identical” to an HOD in another case involving Plaintiff
    Yvonne Huntley. Comparing the two HODs, this Court notes that Plaintiff Yvonne Huntley is
    the guardian for two siblings, both of whom were scheduled for due process hearings on
    February 12, 2008, one at 9:00 a.m. and the other at 11:00 a.m. During the first hearing, the
    Petitioner made an oral motion to consolidate the hearings. (February 22, 2008 HOD at 2.) The
    Hearing Officer granted the motion to consolidate because the “Complaints in both matters were
    filed on the same date, alleged the same single claim, and involved essentially the same set of
    facts. . . .” (Id.) While the HODs are very similar [because the complaints alleged the same
    single claim], this Court finds that the District’s claim of “inadequate documentation” is
    misplaced. Counsel for Plaintiff prepared a complaint on behalf of each sibling and both
    2
    complaints were set for hearings that were consolidated, thus resulting in the issuance of two
    similar but separate HODs. The Court notes that the District makes no claim that the time billed
    for the two HODs or any follow-up on the HODs is duplicative and the time charges billed for
    both are reasonable.
    Plaintiff originally filed her complaint for legal fees and costs with the Small Claims and
    Conciliation Branch of the Superior Court of the District of Columbia. Defendant removed this
    and other simultaneously filed cases to this Court and the parties subsequently consented to the
    referral of all such cases to the undersigned Magistrate Judge for all purposes. The parties were
    directed to brief the issues in these cases in the form of motions for legal fees and responses
    thereto.
    II. LEGAL STANDARD
    The IDEA gives courts authority to award reasonable attorney’s fees to the parents of a
    child with a disability who is the prevailing party. 
    20 U.S.C. §1415
    (i)(3)(B). An action or
    proceeding under IDEA includes both civil litigation in federal court and administrative
    litigation before hearing officers. Smith v. Roher, 
    954 F. Supp. 359
    , 362 (D.D.C. 1997); Moore
    v. District of Columbia, 
    907 F.2d 165
    , 176 (D.C. Cir. 1990), cert. denied, 
    498 U.S. 998
     (1990).
    The plaintiff has the burden of establishing the reasonableness of any fee requests. See
    In re North, 
    59 F.3d 184
    , 189 (D.C. Cir. 1995); Covington v. District of Columbia, 
    57 F.3d 1101
    ,
    1107 (D.C. Cir. 1995) (“[A] fee applicant bears the burden of establishing entitlement to an
    award, documenting the appropriate hours, and justifying the reasonableness of the rates.”) “An
    award of attorneys’ fees is calculated by multiplying a reasonable hourly rate by the number of
    hours reasonably expended on the case.” Smith, 
    954 F. Supp. at
    364 (citing Hensley v.
    3
    Eckerhard, 
    461 U.S. 424
    , 433 (1983)); Blum v. Stenson, 
    465 U.S. 886
    , 888 (1984). The result of
    this calculation is the “lodestar” amount. Smith, 
    954 F. Supp. at 364
    .
    
    20 U.S.C. §1415
    (i)(3)© states that “[f]ees awarded under this paragraph shall be based
    on rates prevailing in the community in which the action or proceeding arose for the kind and
    quality of services furnished.” 
    20 U.S.C. §1415
    (i)(3)©. To demonstrate a reasonable hourly
    rate, the fee applicant must show: an attorney’s usual billing practices; counsel’s skill,
    experience and reputation; as well as the prevailing market rates in the community. Covington,
    
    57 F.3d at 1107
    . The determination of a “market rate for the services of a lawyer is inherently
    difficult” and is decided by the court in its discretion. Blum, 
    465 U.S. at
    896 n.11. “To inform
    and assist the court in the exercise of its discretion, the burden is on the fee applicant to produce
    satisfactory evidence . . . that the requested [hourly] rates are in line with those prevailing in the
    community for similar services by lawyers of reasonably comparable skill, experience and
    reputation.” 
    Id.
     An attorney’s usual billing rate may be considered the “reasonable rate” if it
    accords with the rates prevailing in the community for similar services by lawyers possessing
    similar skill, experience and reputation. Kattan by Thomas v. District of Columbia, 
    995 F.2d 274
    , 278 (D.C. Cir. 1993) (emphasis added).
    A party moving for summary judgment on legal fees accordingly must demonstrate
    prevailing party status and the reasonableness of the fees requested in terms of hours spent and
    hourly rate. Under Fed. R. Civ. P. 56 (a), summary judgment shall be granted if the movant
    shows that there is “no genuine issue as to any material fact and the moving party is entitled to a
    judgment as a matter of law.” Accord Anderson v. Liberty Lobby, Inc., 
    477 U.S. 242
    , 247 (1986).
    Summary judgment should be granted against a party “who fails to make a showing sufficient to
    4
    establish the existence of an element essential to that party’s case, and on which that party will
    bear the burden of proof at trial.” Celotex Corp. v. Catrett, 
    477 U.S. 317
    , 322 (1986).
    The court is required to draw all justifiable inferences in the nonmoving party’s favor and
    to accept the nonmoving party’s evidence as true. Anderson, 
    477 U.S. at 255
    . The nonmoving
    party must establish more than “the mere existence of a scintilla of evidence” in support of its
    position. 
    Id. at 252
    . Nor may the non-moving party rely on allegations or conclusory
    statements; instead, the non-moving party is obliged to present specific facts that would enable a
    reasonable jury to find it its favor. Greene v Dalton, 
    164 F.3d 671
    , 675 (D.C. Cir. 1999).
    III. ANALYSIS
    A. Reasonableness of Hourly Rates
    Plaintiff seeks fees for the services of one lawyer and three paralegals, to be paid at the
    following rates: $268.00/$275.00 per hour for Zachary Nahass, an attorney with approximately
    1-2 years experience during the relevant time period, and $146.00/$150.00 per hour for Patrick
    Meehan, Yanet Scott and Camille McKenzie, who were paralegals with the firm Tyrka &
    Associates during that same period of time.3 (Plaintiff’s Itemization of Fees/Expenses, attached
    to Notice of Removal [1]; Fee Motion [10], Exh. 2 [Verified Statement of Douglas Tyrka
    (“Tyrka”)] ¶¶ 8 -11, 15.) According to Tykra’s Verified Statement (“Verified Statement”),
    “[t]he hourly rates in the itemization are the rates Tyrka & Associates has customarily charged.”
    (Exh. 2 ¶4.)
    Tyrka further asserts that “clients have retained Tyrka & Associates with the
    3
    The law firm’s hourly rate for paralegal charges occurring after May 31, 2008 increased
    from $146/hour to $150/hour, even though the “enhanced” Laffey Matrix rates increased from
    $146/hour to $152/hour during that same time. Similarly, Mr. Nahass’s hourly rate would have
    increased from $268/hour to $279/hour based on the “enhanced” Laffey Matrix.
    5
    understanding and agreement that the client would retain full responsibility for all fees regardless
    of what was reimbursed by third parties, at rates consistent with ‘the Laffey [M]atrix’ as adjusted
    per the finding in Salazar v. District of Columbia, 
    123 F. Supp. 2d 8
    , 14-15 (D.D.C. 2000), and
    other cases.” (Exh. 2 ¶4.)4 Plaintiff relies upon the rates set forth in the “enhanced” Laffey
    Matrix in her request for attorney’s fees but Tyrka’s Verified Statement does not indicate how
    frequently Plaintiff’s counsel is paid at these “enhanced” Laffey rates.5 Nor has counsel
    presented affidavits attesting to the actual billing rates of lawyers who do similar IDEA work.
    Furthermore, the Plaintiff has not provided specific information about the nature or complexity
    of the IDEA administrative work performed in this case.
    Plaintiff asserts that in order to demonstrate prevailing market rates, she may “point to
    such evidence as an updated [enhanced] version of the Laffey Matrix or the U.S. Attorney’s
    Office [“USAO”] Matrix, or [her] own survey of prevailing market rates in the community.”
    4
    The Laffey Matrix is “a schedule of charges based on years of experience” developed in
    Laffey v. Northwest Airlines, Inc., 
    572 F. Supp. 354
     (D.D.C. 1983), rev’d on other grounds, 
    746 F.2d 4
     (D.C. Cir. 1984), cert. denied, 
    472 U.S. 1021
     (1985), as modified by Save Our
    Cumberland Mountains, Inc. v. Hodel, 
    857 F.2d 1516
    , 1524 (D.C. Cir. 1988). The Laffey Matrix
    was first developed based upon information about the prevailing rates charged for complex
    federal litigation in the District of Columbia, and it is maintained by the United States Attorney’s
    Office for the District of Columbia and is updated annually to reflect increases in the local
    Consumer Price Index. See Laffey Matrix - 2003-2012, n.3, available at:
    htttp://www.justice.gov/usao/dc/divisions/civil_Laffey_Matrix_2003-2012.pdf.
    The “enhanced” Laffey Matrix is a schedule of fees based on the original Laffey Matrix, with
    adjustments to reflect increases in the national Legal Services Index, prepared by the United
    States Bureau of Labor Statistics. (Fee Motion, Exh.3.)
    5
    See generally MacClarence v. Johnson, 
    539 F.Supp.2d 155
    , 160 (D.D.C.
    2008)(expressing concern that “standardized hourly rates overcompensate lawyers whose
    practices are contingent fee based and therefore compensated at an hourly rate they never charge
    and none of their clients could pay”).
    6
    (Memorandum in support of Fee Motion (“Memorandum”) at 8 (citing Covington, 
    57 F.3d at 1109
     (additional citation omitted))). In the Covington case, which involved allegations of civil
    rights violations, the Court of Appeals for the D. C. Circuit did look to Laffey rates for prevailing
    market rates but the relevant market therein was “complex federal litigation,” 
    57 F.3d at 1110
    .
    In contrast, this case involves IDEA litigation, which is not complex federal litigation because
    most if not all of the attorney’s fees in question are the result of counsel’s preparation for
    attendance at routine administrative hearings. Accordingly, the Laffey Matrix rates are
    inapplicable as prevailing market rates.
    Plaintiff additionally relies upon Rooths v District of Columbia, Civil Action No. 09-
    0492, Report and Recommendation of March 31, 2011, and Friendship Edison Pub. Charter
    Sch. v. Suggs, Civil Action No. 06-1284, Motion for Attorneys’ Fees of July 10, 2008 and
    Memorandum Opinion of March 30, 2009 at 5-8. (Fee Motion, Exhs. 5-7).6 According to
    Plaintiff, in these two IDEA cases litigated in this United States District Court, the firm’s clients
    received an award of fees “based on rates exactly in line with those presented here, . . . ”
    (Memorandum at 8.)
    As a preliminary matter, this Court notes that the mere showing that a high hourly rate
    was approved in another case does not in and of itself establish a new market rate or prove that
    the new rate is reasonable. Furthermore, Plaintiff’s reliance on Rooths v District of Columbia,
    Civil Action No. 09-0492, Report and Recommendation of March 31, 2011 at 10-11 (Fee
    6
    Plaintiff relies on Friendship Edison Pub. Charter Sch. v. Suggs, Civil Action No. 06-
    1284, Motion for Attorneys’ Fees of July 10, 2008 and Memorandum Opinion of March 30,
    2009 at 5-8, but this case is inapposite because there was no challenge to the reasonableness of
    the hours expended by counsel or the hourly rates in that case.
    7
    Motion, Exh. 5), is misplaced because the trial court ultimately rejected the application of
    enhanced Laffey rates, applied Laffey Matrix rates as a starting point, and then reduced those
    rates by 25%. Rooths v District of Columbia, 
    802 F.Supp.2d 56
    , 63 (D.D.C. 2011).
    In Rooths, the Honorable Paul L. Friedman noted that “[i]n this circuit, the rates
    contained in the Laffey Matrix are typically treated as the highest rates that will be presumed to
    be reasonable when a court reviews a petition for statutory attorneys’ fees.” 802 F Supp. 2d 61.
    The trial court declined “to approve as reasonable the inflated rates contained in a proposed
    alternative fee matrix.” Id.; see Blackman v. District of Columbia, 
    677 F. Supp. 2d 169
    , 176
    (D.D.C. 2010) (in determining prevailing market rates, the court declined to apply enhanced
    Laffey rates). The Rooths court further refused to apply enhanced Laffey rates, in part because it
    found that the “[enhanced Laffey] matrix was generated using national statistics rather than
    measurements particular to the District of Columbia area.” 802 F. Supp.2d at 62 (emphasis in
    original); see also DL v. District of Columbia, 
    256 F.R.D. 239
    , 243 (D.D.C. 2009) (because the
    USAO [Laffey] Matrix accounts for price inflation within the local community, it more aptly
    focuses on the relevant community than the [enhanced] Laffey Matrix based on the legal services
    index). The Rooths court commented that “[w]hile it is doubtless true that some sectors of the
    legal services industry have experienced rapid fee inflation in recent years, [it was] unconvinced
    that fees associated with IDEA litigation in the District of Columbia have increased at the same
    rate.” 802 F. Supp. 2d at 62.
    Recognizing the difficulty courts encounter in determining what are reasonable legal
    fees, this Court agrees with the rationale set forth in Rooths, and finds that the Plaintiff’s reliance
    on an enhanced Laffey Matrix is unsupported because such Matrix does not provide an accurate
    8
    representation of District of Columbia legal fees applicable to IDEA cases. Nor has Plaintiff
    demonstrated that IDEA litigation involving administrative hearings is the type of “complex
    federal litigation” encompassed by the Laffey rates. See McClam v. District of Columbia, Civil
    Action No. 11-381 (RMC), September 6, 2011 Memorandum Opinion at 8 (declining to apply
    Laffey rates in part on grounds that “IDEA cases are generally not complex [and in that case,]
    Plaintiffs . . . pointed to no novel issue or other complexity that turned this, particular IDEA
    case into a complicated piece of litigation.”)7
    Defendant’s argument against imposition of Laffey rates primarily focuses on the Rooths
    and McClam decisions, supra. but the Defendant also asserts that “Plaintiffs have made no
    serious attempt to show that rates under the Laffey Matrix are appropriate in this case or, more
    specifically, that Laffey rates were necessary to attract competent counsel in the underlying,
    special education matters.” (Opposition at 13.)8 Defendant further argues that there is no
    “inherent right to Laffey rates.” (Opposition at 13 (citation omitted)); see Lively v Flexible
    Packaging Assoc., 
    930 A.2d 984
    , 990 (D.C. 2007) (accepting the Laffey Matrix as one legitimate
    means of calculating attorney’s fees and using it as a starting point instead of an automatic
    application). Federal courts do not automatically have to award Laffey rates but instead they can
    look at the complexity of the case and use their discretion to determine whether such rates are
    7
    The McClam court acknowledged that “[f]ederal district courts in this circuit disagree
    whether Laffey rates should be applied in IDEA cases.” McClam Memorandum Opinion at 6
    (citations omitted).
    8
    See Kenny A. v. Perdue, 
    130 S. Ct. 1662
    , 1672 (2010) “a ‘reasonable’ fee is a fee that is
    sufficient to induce a capable attorney to undertake the representation of a meritorious civil
    rights case”); see also Lively v. Flexible Packaging Association, 
    930 A.2d 984
    , 990 (D.C. 2007)
    (cautioning that the goal of fee-shifting provisions is not to provide counsel with a windfall but
    to attract competent counsel).
    9
    warranted. See Muldrow v. Re-Direct, Inc., 
    397 F. Supp. 2d 1
    , 4-5 (D.D.C. 2005) ( awarding
    fees at a rate 25% less than Laffey in a “relatively straightforward negligence suit”).
    This Court follows the reasoning of the Rooths case and other cases declining to apply
    enhanced Laffey rates. Considering that this is a straightforward case seeking IDEA legal fees,
    this Court concludes that the Plaintiff has failed to demonstrate that the hourly rates set by her
    counsel, which are based on enhanced Laffey rates, are reasonable.9 Such enhanced rates do not
    reflect what the local legal market will bear in terms of legal fees for IDEA litigation. Using the
    [USAO] Laffey Matrix as a starting point for determination of a reasonable hourly rate, this
    Court determines that the hourly rate for Zachary Nahass [attorney with 2 years experience]
    would be $215.00/$225.00, instead of $268.00/$275.00, while the rate for a paralegal [Patrick
    Meehan, Yanet Scott and Camille McKenzie] would be $125.00/$130.00 instead of
    $146.00/$150.00.
    These rates should be further reduced however because the Laffey Matrix rates are the
    presumed maximum rates appropriate for “complex federal litigation,” Covington v. District of
    Columbia, 
    57 F.3d at 1103
    , and IDEA litigation generally does not fall within that category. The
    case at issue is no exception to that general rule insofar as it involves a routine administrative
    proceeding summarized in the Hearing Officer’s Decision dated February 22, 2008 (HOD [1])
    and the time spent [billed] in preparation for the hearing was nominal. (Itemization of
    Fees/Expenses.) In such a case, an hourly rate below the Laffey Matrix rates is appropriate. See
    Wilson v. District of Columbia, Civil Action No. 09-2258, 
    2011 WL 1428090
    , at *3 (D.D.C.
    9
    By statute the Court determines the reasonableness of the hourly rate for the legal fees.
    The negotiated legal fee hourly rate between the attorney and his client may be more or less than
    the hourly rate set by the Court.
    10
    Apr. 14, 2011) (Laffey Matrix is “not generally applicable to IDEA cases because they are not
    usually complex”); A.C. ex rel. Clark v. District of Columbia, 
    674 F.Supp.2d 149
    , 155 (D.D.C.
    2009) (finding the USAO Laffey inapplicable in an IDEA case where “almost all of the
    attorney’s fees in question are the result of counsel’s preparation for attendance at routine
    administrative hearing”); Agapito v. District of Columbia, 
    525 F.Supp.2d 150
    , 155 (D.D.C.
    2007) (adjusting attorney fee award and declining to rely on the Laffey Matrix for these
    “relatively simple and straightforward IDEIA cases”). The Court will therefore award fees at an
    hourly rate equal to three-quarters of the USAO Laffey Matrix rate, which is $161.00/$169.00 for
    Nahass and $94.00/98.00 for Meehan, Scott and McKenzie10
    B. Challenges to Time Charges
    Defendant claims that some of the hours billed by Plaintiff’s counsel should not be
    compensated because they are too remote in time as to “preclude a meaningful relationship with
    the hearing.” (Opposition at 16, citing Czarniewy v. District of Columbia, 
    2005 U.S. Dist. LEXIS 5161
    , at *11 (D.D.C. March 25, 2005)). See also Role Models America, Inc. v.
    Brownlee, 
    353 F.3d 962
    , 973 (D.C. Cir. 2004) (where administrative fee charges have no
    temporal proximity to the proceeding on which the right to fees is based but instead appear to be
    administrative matters between counsel and his client, these charges are not appropriate for
    reimbursement). Defendant asserts that “[t]he statute does not contemplate an undefined form of
    ongoing representation of students [but instead] [i]t quantifies the activities for which school
    10
    Defendant notes that a 25% reduction in Laffey Matrix rates brings these fees in line
    with its DCPS Fee Guidelines (Opposition at 15); however, it is not the intent of this Court to
    mirror the DCPS Fee Guidelines but instead to apply a percentage reduction that represents the
    fact that most IDEA litigation [involving administrative proceedings] is not complex federal
    litigation warranting the application of Laffey Matrix rates.
    11
    districts are obliged to reimburse legal representation to the administrative process described in
    
    20 U.S.C. §1415
    . . . .” (Opposition at 16.)
    A review of the time sheets submitted by Plaintiff shows that the time charges noted by
    counsel have sufficient temporal proximity to the date of the HOD. Some of the time entries
    pre-date and include the due process hearing, reflecting preparation for and attendance at the
    hearing; several time entries note the hearing and counsel’s actions taken in response to the
    Hearing Officer’s Determination; and finally, some time entries following the HOD reflect
    follow-up by
    counsel, including time spent ensuring HOD compliance. This Court will not further reduce
    time charges based on Defendant’s claim that some charges are remote.
    C. Costs
    Plaintiff seeks costs in the amount of $77.60 for expenses arising from copying ($.10 per
    page) and faxing ($1.00 per page). Costs for copying, faxing and postage are customarily
    included in fee awards in IDEA litigation. Kaseman v. District of Columbia, 
    329 F. Supp. 2d 20
    ,
    28 n.7 (D.D.C. 2004). These total costs are not contested by the Defendant and will be awarded
    to the Plaintiff.
    D. Fees and Costs Awarded
    The amount of fees and costs requested by Plaintiff is $1,412.35, which can be broken
    down into $1,334.75 for legal fees, and $77.60 for costs. The legal fees claimed were based on
    3.25 hours billed at $268.00/hour, .75 hour billed at $275.00/hour, 1.25 hours billed at
    $146.00/hour and .5 hours billed at $150.00/hour. This Court has determined that hourly rates
    based on 75% of the Laffey Matrix rate are applicable, which means that 3.25 hours are billed at
    12
    $161.00/hour, .75 hour is billed at $169.00/hour, 1.25 hours are billed at $94.00/hour and .5 hour
    is billed at $98.00/hour. Total fees thus equal $816.50, and total costs equal $77.60, which
    together total $894.10
    DATED: May 8, 2012                                  _____________/s/____________________
    ALAN KAY
    UNITED STATES MAGISTRATE JUDGE
    13
    

Document Info

Docket Number: Civil Action No. 2011-0163

Judges: Magistrate Judge Alan Kay

Filed Date: 5/9/2012

Precedential Status: Precedential

Modified Date: 2/19/2016

Authorities (21)

Sarah Kattan, by Her Parents and Next Friends Susan J. ... , 995 F.2d 274 ( 1993 )

In Re Oliver L. North (Bush Fee Application) , 59 F.3d 184 ( 1995 )

Lani Moore v. District of Columbia , 907 F.2d 165 ( 1990 )

Save Our Cumberland Mountains, Inc. v. Donald P. Hodel, ... , 857 F.2d 1516 ( 1988 )

Role Models Amer Inc v. White, Thomas , 353 F.3d 962 ( 2004 )

darryl-covington-tracy-dew-bey-david-edwards-lee-roy-ferguson-raymond-gant , 57 F.3d 1101 ( 1995 )

Lively v. Flexible Packaging Ass'n , 930 A.2d 984 ( 2007 )

Smith v. Roher , 954 F. Supp. 359 ( 1997 )

Kaseman v. District of Columbia , 329 F. Supp. 2d 20 ( 2004 )

Laffey v. Northwest Airlines, Inc. , 572 F. Supp. 354 ( 1983 )

Agapito v. District of Columbia , 525 F. Supp. 2d 150 ( 2007 )

MacClarence v. Johnson , 539 F. Supp. 2d 155 ( 2008 )

A.C. Ex Rel. Clark v. District of Columbia , 674 F. Supp. 2d 149 ( 2009 )

Muldrow v. Re-Direct, Inc. , 397 F. Supp. 2d 1 ( 2005 )

Anderson v. Liberty Lobby, Inc. , 106 S. Ct. 2505 ( 1986 )

Celotex Corp. v. Catrett, Administratrix of the Estate of ... , 106 S. Ct. 2548 ( 1986 )

Perdue v. Kenny A. Ex Rel. Winn , 130 S. Ct. 1662 ( 2010 )

Hensley v. Eckerhart , 103 S. Ct. 1933 ( 1983 )

Blackman v. District of Columbia , 677 F. Supp. 2d 169 ( 2010 )

Salazar v. District of Columbia , 123 F. Supp. 2d 8 ( 2000 )

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