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Doe v. Board of Educ. of the Gates/Chili Cent. Sch. Dist.
No. 91-CV-6209L (W.D.N.Y. June 2, 1995) ; Clearinghouse Number: 50752
Description
Child with Physical Disability and Excluded from Athletics by School Is Awarded over $37,000 in Fees`
Abstract
The district court has awarded plaintiffs attorney fees in this
class action against defendant school district’s exclusion of
children with disabilities from extracurricular activities solely
because of their physical impairments. Defendant acted in
accordance with a state law authorizing a school district to
exclude a “physically impaired child” from school
athletics without first considering whether or not the child is
otherwise qualified to participate. Plaintiffs claimed that this
provision was unconstitutional under the Supremacy Clause because
section 504 of the Rehabilitation Act of 1973 prohibits
discrimination under any federally funded program or activity. The
case was settled by consent decree after defendant adopted a new
policy on participation in athletics by students with physical
disabilities. Subsequently, plaintiff sought over $37,000 in
attorney fees and costs. Defendant argued that plaintiffs were
entitled only to fees related to relief that could have been
obtained in the form of an enforceable judgment against defendant;
since the court could not have ordered it to adopt any policy on
physically impaired students, plaintiffs should not receive fees
incurred in negotiating the new policy. Furthermore,
plaintiffs’ fee request should be lowered because their
attorneys had not exercised prudent billing judgment. Rejecting
these arguments, the court noted that many portions of
plaintiffs’ fee request had been substantially reduced and
that much of the time claimed could be attributed to
defendant’s actions and its positions in litigation and in
response to plaintiffs’ fee request. Courts may order parties
to correct constitutional or statutory violations, and defendant
had offered no cogent reason why plaintiffs should not be awarded
some fees for time reasonably spent on that aspect of the case.
Accordingly, the court awarded plaintiffs the full amount of
attorney fees and costs requested.
