Clarifying “By Reason Of” Causation under Title II of the ADA and Proportional Fee Reductions under the ADA and Rehabilitation Act

Introduction

This commentary examines the Second Circuit’s summary order in Spring v. Allegany-Limestone Central School District, Nos. 23-7821, 24-1926 (2d Cir. Apr. 10, 2025). The appeal arose from the removal of a high-school student, Gregory Spring, from his soccer team after he displayed Tourette’s-related tics and used profanities. Plaintiffs (the Springs) sued the School District and its officials under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, alleging discrimination “by reason of” Gregory’s disability. The District Court denied the defendants’ post-trial motions and awarded the Springs attorneys’ fees, later reducing them by 80%. On appeal, the Second Circuit affirmed in part, vacated and remanded in part, clarifying two core principles:

The “by reason of” (motivating factor) causation standard applies to Title II ADA and Rehabilitation Act discrimination claims.
Fee reductions must be proportionate to actual deficiencies and the degree of success achieved, not imposed as across-the-board slashes.

Summary of the Judgment

The Second Circuit—sitting by summary order—held that:

The evidence was legally sufficient for a jury to find that Gregory Spring was “disabled” under the ADA and Rehabilitation Act (42 U.S.C. § 12102; 29 U.S.C. § 794) and that the School District discriminated against him because his disability was a “motivating factor” in the decision to remove him from the team.
The District Court had not erred in denying the defendants’ motions for judgment as a matter of law (Fed. R. Civ. P. 50) or a new trial.
The District Court abused its discretion in reducing the Springs’ fee award by 80%; the reduction was neither tied to the limited success nor to the specific billing deficiencies in a proportionate way. The order as to fees was vacated and remanded for recalculation.

Analysis

Precedents Cited

Palin v. New York Times Co., 113 F.4th 245 (2d Cir. 2024) – standard of review for judgment as a matter of law (de novo).
B.C. v. Mount Vernon Sch. Dist., 837 F.3d 152 (2d Cir. 2016) – Rehabilitation Act incorporates the ADA’s definition of “disability.”
Sedor v. Frank, 42 F.3d 741 (2d Cir. 1994) – conduct caused by a disability can establish a causal link in discrimination claims.
Wright v. Memphis Light, Gas & Water Div., 558 F. App’x 548 (6th Cir. 2014) – stuttering substantially limits major life activities.
Hensley v. Eckerhart, 461 U.S. 424 (1983) – lodestar method and plaintiff’s burden to document hours and rates in fee awards.
Grant v. Martinez, 973 F.2d 96 (2d Cir. 1992) – baseline for lodestar approach in this Circuit.
Raja v. Burns, 43 F.4th 80 (2d Cir. 2022) – percentage deductions must be tied to specific billing deficiencies.
Kirsch v. Fleet St., Ltd., 148 F.3d 149 (2d Cir. 1998) – district courts may deduct a “reasonable percentage” for inefficiencies.

Legal Reasoning

The panel began by clarifying the causation standard under Title II of the ADA (42 U.S.C. § 12132) and the Rehabilitation Act (29 U.S.C. § 794), adopting the “motivating factor” approach for “by reason of” disability discrimination. It held that:

Testimony showed Gregory had Tourette’s and callosal dysgenesis that substantially limited major life activities—especially communicating and concentrating.
His foul-language tics and impulsive reactions were directly linked to his neurological impairments.
School officials acted because of those manifestations—removing him from the team for “what he said” and “the way he acted”—despite prior warnings in his Individualized Education Program (IEP) and parental notice.

On attorneys’ fees, the court emphasized that reductions under Hensley must align with:

The degree of success (Holick v. Cellular Sales; Barfield v. NYC Health & Hosps. Corp.).
Specific billing deficiencies identifiable from the record (Raja v. Burns).

The 80% cut here was excessive because the District Court could—and did—identify particular vague entries and double billing, yet applied a global slash without proportionally tying the reduction to the actual problems or to the plaintiff’s overall success, which included a successful appellate reversal of pre-trial dismissals.

Impact

This decision provides guidance on two fronts:

It cements that a “motivating factor” standard governs Title II ADA and Rehabilitation Act discrimination claims, aligning them with Title I jurisprudence in many Circuits (though “but-for” remains unsettled elsewhere).
It underscores that courts must calibrate fee reductions carefully—quantifying billing deficiencies and comparing the plaintiff’s requested relief to actual results—lest the reduction be deemed an abuse of discretion.

Complex Concepts Simplified

Title II ADA & Rehabilitation Act “disability”: A “physical or mental impairment” that substantially limits major life activities (e.g., speaking, concentrating). If a condition causes involuntary tics or stutters, it may qualify.
“By reason of” discrimination: Requires showing the disability was a motivating factor in the adverse action. In practice, if officials know about the disability and react to its manifestations, that link can be established.
Lodestar method: A fee calculation tool: (reasonable hours) × (reasonable hourly rate) = “lodestar.” Adjustments reflect success level and billing quality.
Percentage reduction: A shortcut to trim fees for inefficiencies—but only where entries are so vague or duplicative that item-by-item review is impossible.

Conclusion

Spring v. Allegany-Limestone Central School District offers two key lessons:

Disability discrimination under Title II and the Rehabilitation Act encompasses actions taken “by reason of” disability-related conduct, assessed under a “motivating factor” standard.
Attorneys’ fee awards must be reduced in proportion to identifiable inefficiencies and the actual success achieved—blanket percentage cuts risk reversal on appeal.

Taken together, the ruling provides practitioners with concrete benchmarks for proving causal discrimination in public-entity cases and for crafting or contesting fee petitions in ADA and Rehabilitation Act litigation.