Defining “Disability” and “Motivating Factor” Causation Under Title II of the ADA and Limits on Fee Reductions: Spring v. Allegany-Limestone Central School District

Introduction

The Second Circuit’s summary order in Spring v. Allegany-Limestone Central School District addresses two main issues: (1) whether the evidence at trial supported a finding that the decedent, Gregory Spring, was “disabled” under Title II of the Americans with Disabilities Act (ADA) and the Rehabilitation Act and whether the school district’s decision to remove him from a sports team was motivated by that disability, and (2) whether the district court abused its discretion by reducing the plaintiffs’ attorney’s fee award by 80%. The parties are:

Plaintiffs-Appellees: Keri Spring (administrator of the estate of Gregory Spring), Eugene Spring, and Julianne Spring
Defendants-Appellants: Allegany-Limestone Central School District, its Board of Education, and Principal Kevin Straub

At the district court, a jury found for the Springs on their ADA and Rehabilitation Act claims, and the district court later reduced their fee award by 80%. On appeal, Allegany-Limestone challenged the sufficiency of the evidence and the denial of post-trial motions, while the Springs cross-appealed the fee reduction.

Summary of the Judgment

The Second Circuit held:

Sufficiency of Evidence: The trial evidence was legally sufficient to support a finding that Gregory had a qualifying disability (Tourette’s syndrome and callosum dysgenesis that substantially limited his ability to speak and communicate) and that his removal from the team was motivated by conduct caused by that disability.
Post-Trial Motions: The district court did not err in denying judgment as a matter of law under Federal Rule of Civil Procedure 50(a) or in denying a new trial under Rule 59.
Attorney’s Fees: The district court abused its discretion by reducing the Springs’ fee award by an “unusually large” 80%. The court vacated the fee award and remanded for a recalculation in a proportionate manner, consistent with the degree of success and identifiable billing deficiencies.

Analysis

1. Precedents Cited

Palin v. New York Times Co. (2024) – standard of review for judgment as a matter of law in the Second Circuit.
B.C. v. Mount Vernon School District (2016) – Rehabilitation Act incorporates ADA’s definition of “disability.”
Sedor v. Frank (1994) – causation under ADA: conduct caused by disability may motivate adverse action.
Wright v. Memphis Light, Gas & Water Div. (2014) – stutter held to substantially limit the major life activity of speaking.
Hensley v. Eckerhart (1983) – lodestar method and burden on fee applicant to document hours and rates.
McDonald ex rel. Prendergast (2006), Grant v. Martinez (1992) – trial court’s discretion in fee awards and use of percentage deductions.
Raja v. Burns (2022) – limits on across-the-board fee cuts when deficiencies are identifiable.
Kirsch v. Fleet Street (1998) – “reasonable percentage” reductions in fees must relate to actual deficiencies.

2. Legal Reasoning

Defining “Disability” and Causation: Title II of the ADA and Section 504 of the Rehabilitation Act prohibit discrimination “by reason of” or “solely by reason of” disability. The court applied the ADA’s definition: an impairment that “substantially limits” one or more major life activities, including speaking and communicating (42 U.S.C. § 12102(1)-(2)). Testimony showed that Gregory’s Tourette’s and callosum dysgenesis caused involuntary tics, verbal outbursts, and difficulty putting thoughts into words, supporting the finding of a disability.

The court also applied the “motivating factor” test (assumed but not squarely decided here) for causation: conduct caused by the disability (verbal outbursts) motivated removal from the team, despite prior notice to the school of Gregory’s condition.

Attorney’s Fees and Proportionality: Under 42 U.S.C. § 12205, a prevailing ADA plaintiff may recover “reasonable attorney’s fees.” The lodestar approach—reasonable hours multiplied by reasonable rates—serves as the starting point. While courts may trim “fat” by percentage deduction, any reduction must closely track identifiable billing deficiencies or relate to the degree of success. Here, the district court identified some vague entries and double billing but applied an excessive 80% across-the-board cut without proportional analysis, requiring remand.

3. Impact

Clarifies that neurological speech disorders (e.g., Tourette’s) can qualify as disabilities limiting communication under the ADA/Rehabilitation Act.
Reaffirms that adverse actions motivated by disability-related conduct are actionable, even if the conduct itself is disruptive.
Limits on fee reductions: trial courts must tie percentage cuts to specific billing deficiencies or to the actual degree of success, not apply broad, arbitrary reductions.
Guidance for litigants: fully document hours and rates, flag entries that may be challenged, and articulate the relationship between each claim and the relief obtained.

Complex Concepts Simplified

Judgment as a Matter of Law (Rule 50): A motion asserting that no reasonable jury could find for the non-moving party on the evidence presented.
Motivating Factor Test: A plaintiff must show that the disability was a causal factor in the adverse decision, even if not the sole cause.
Lodestar Method: The calculation of attorneys’ fees by multiplying reasonable hours by a reasonable hourly rate.
Percentage Deduction: A shortcut to reduce fees for inefficiency but must be proportionate to actual deficiencies identified.

Conclusion

The Second Circuit’s decision in Spring v. Allegany-Limestone offers important guidance on two fronts. First, it confirms that impairments affecting speech and communication—such as Tourette’s syndrome—fall within the ADA’s definition of “disability,” and that removal from school activities motivated by disability-related conduct can constitute unlawful discrimination. Second, in the fee-shifting context, courts must ensure that any percentage reduction is proportionate to documented inefficiencies or the degree of success achieved. This ruling underscores careful record-keeping by counsel and precise, principled reductions by courts when trimming fee requests.