Ensuring Proportionality in ADA Fee Awards: Reaffirming the Lodestar Method and Limiting Across-the-Board Reductions

Introduction

This commentary examines the Second Circuit’s April 10, 2025 summary order in Spring v. Allegany-Limestone Central School District, 23-7821, 24-1926 (2d Cir. 2025). Plaintiffs Keri Spring (administrator of Gregory Spring’s estate), Eugene Spring, and Julianne Spring (collectively “the Springs”) sued a public school district under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. They alleged that the district discriminated against Gregory—a student with Tourette’s syndrome and related conditions—by removing him from a sports team on account of speech and behavioral tics. After a jury verdict for Plaintiffs, the district court denied the school’s motions for judgment as a matter of law and a new trial but cut the Springs’ attorney’s fees by 80%. The School and the Springs both appealed.

Summary of the Judgment

The Second Circuit affirmed the denial of the School’s motions for judgment as a matter of law and for a new trial. It held that there was legally sufficient evidence both that Gregory was “disabled” under the ADA and Rehabilitation Act and that the district discriminated against him “by reason of” his disability.
The court vacated the district court’s 80% across-the-board reduction in attorney’s fees and remanded for a more granular assessment. It concluded that such a steep cut was not supported by the record where the district court could—and did—identify specific billing deficiencies and had to make a proportional reduction.

Analysis

1. Precedents Cited

Palin v. New York Times Co., 113 F.4th 245 (2d Cir. 2024): Standard of review for denial of judgment as a matter of law; evidence must be viewed in the light most favorable to the non-movant.
B.C. v. Mount Vernon School District, 837 F.3d 152 (2d Cir. 2016): ADA and Rehabilitation Act share the same definition of “disability.”
Sedor v. Frank, 42 F.3d 741 (2d Cir. 1994): Conduct caused by a disability may establish causation in a discrimination claim.
Hensley v. Eckerhart, 461 U.S. 424 (1983): Lodestar method for calculating reasonable attorney’s fees.
McDonald ex rel. Prendergast v. Pension Plan of the NYSA-ILA Pension Trust Fund, 450 F.3d 91 (2d Cir. 2006): Abuse-of-discretion review of fee awards; percentage cuts may be used to trim inefficiencies.
Raja v. Burns, 43 F.4th 80 (2d Cir. 2022): Limits on across-the-board reductions; reductions must be proportionate and tied to identified deficiencies.
Kirsch v. Fleet St., Ltd., 148 F.3d 149 (2d Cir. 1998): District court must choose a “reasonable percentage” deduction when trimming fees.

2. Legal Reasoning

Disability and Discrimination: The court applied the ADA’s definition: a “physical or mental impairment that substantially limits one or more major life activities.” Evidence showed that Tourette’s and callosal dysgenesis substantially limited Gregory’s ability to speak, process thoughts, and regulate emotional responses. His verbal tics (e.g., involuntary profanity) and impulsive reactions supported a disability finding.

On discrimination, the panel assumed—without resolving—that Title II uses a “motivating factor” causation test. The record demonstrated that school officials ejected Gregory from the sports team because of his outbursts—precisely the behavior his mother had warned was tied to his disability. Under Second Circuit precedent, conduct caused by a disability can establish discriminatory intent.

Attorney’s Fees: The ADA authorizes “reasonable attorney’s fees.” The lodestar method (hours × reasonable rate) is the starting point, but district courts may make percentage reductions to eliminate inefficiency or insufficient success. Here, the district court slashed the Springs’ lodestar by 80%, citing (1) claims that were dismissed prior to trial and (2) vague or overlapping time entries. The Second Circuit held that such a large, undifferentiated cut was unwarranted because the court had already pinpointed specific billing issues and the Springs obtained significant relief—both at trial and on appeal.

3. Impact on Future Cases

This decision reinforces two rules:

Judges must tie fee reductions to identifiable deficiencies and calibrate cuts proportionately rather than impose sweeping percentages.
In Title II ADA cases, lower courts may rely on evidence of conduct caused by a disability to establish both the existence of a disability and discriminatory intent—even under a “motivating factor” standard.

Complex Concepts Simplified

Lodestar Method: A calculation of attorney’s fees by multiplying the number of hours reasonably worked by a reasonable hourly rate.
Motivating Factor Test: A plaintiff need only show that the forbidden trait (here, disability) was one of the reasons for the adverse decision.
Judgment as a Matter of Law (JMOL): A post-verdict motion arguing that no reasonable jury could have legally found for the other side.
Summary Order: A non-precedential decision that still guides parties and courts on the court’s approach to controlling law.

Conclusion

The Second Circuit’s ruling in Spring v. Allegany-Limestone underscores the principle that fee awards under the ADA must be both transparent and proportionate. A district court may—and should—identify and exclude wasteful or duplicative billing entries, but any overall reduction must reflect the court’s detailed findings and the degree of success obtained. On the merits, the decision affirms that courts will protect students with disabilities from discriminatory treatment, even when their disability manifests as challenging behavior. This summary order thus provides valuable guidance for litigants and judges navigating ADA fee petitions and discrimination claims under Title II.