Proportionality in ADA Fee Awards and Recognition of Communication Disabilities Under Title II

Introduction

Spring v. Allegany-Limestone Central School District is a 2025 decision of the United States Court of Appeals for the Second Circuit. The case arises from the removal of a high-school student, Gregory Spring, from his school’s sports team. Gregory, who suffered from Tourette’s syndrome and callosum dysgenesis, was accused of kicking another student during a “game” and then using profanity and exhibiting disruptive behavior when confronted by his coach. The student’s administrator and school district moved to exclude him from athletics. Gregory’s family sued under Title II of the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act, alleging that the school district discriminated against him because of his disability. After a jury verdict in favor of the Springs, the defendants challenged the verdict and the district court reduced the Springs’ attorney’s fee award by 80%. The Springs appealed the fee reduction; the school district cross-appealed the denial of its motions for judgment as a matter of law and for a new trial.

Summary of the Judgment

The Second Circuit affirmed in part, vacated in part, and remanded. It held that:

There was legally sufficient evidence for a jury to conclude that Gregory’s Tourette’s syndrome and callosum dysgenesis substantially limited his ability to communicate—a “major life activity” under the ADA and Rehabilitation Act.
The school district’s removal of Gregory from the team was motivated, at least in part, by his disability-related behaviors (profane outbursts and impulsive reactions) and thus constituted unlawful discrimination under Title II of the ADA and § 504 of the Rehabilitation Act.
The district court did not abuse its discretion in denying the school district’s post-trial motions for judgment as a matter of law or for a new trial.
By contrast, the district court’s 80% across-the-board reduction of the Springs’ $451,688.92 fee application was an abuse of discretion because it was disproportionate to the identified billing deficiencies and to the degree of success achieved by the Springs, including appellate victories.

Analysis

Precedents Cited

The Second Circuit relied on—and distinguished among—a number of key authorities:

Palin v. New York Times Co. (113 F.4th 245): Standard of review for judgment as a matter of law under Federal Rule of Civil Procedure 50.
B.C. v. Mount Vernon School District (837 F.3d 152): Definition of “disability” under ADA §§ 12102(1)–(2) and incorporation in the Rehabilitation Act.
Wright v. Memphis Light, Gas & Water Div. (558 F. App’x 548): Recognition that speech impediments or tics can substantially limit the major life activity of “speaking.”
Sedor v. Frank (42 F.3d 741): Causation standard for discrimination under the ADA when disability-related conduct motivates adverse action.
Hensley v. Eckerhart (461 U.S. 424): Lodestar method and standards for attorney’s fee awards in civil rights cases.
McDonald ex rel. Prendergast v. Pension Plan (450 F.3d 91): Permissibility of percentage reductions to trim “fat” from fee applications.
Raja v. Burns (43 F.4th 80): Limits on across-the-board fee cuts and requirement that reductions be proportionate to identified deficiencies.

Legal Reasoning

Disability and Discrimination: Under Title II of the ADA and § 504 of the Rehabilitation Act, a “public entity” may not discriminate “by reason of” disability. Disability is defined to include a physical or mental impairment that “substantially limits” a major life activity such as communicating. The court accepted testimony that Gregory’s Tourette’s and callosum dysgenesis caused speech blocks, profane tics, anxiety, and impulsive reactions. A reasonable jury could find that these conditions substantially limited his ability to speak and to process information.

The defendants conceded the “motivating factor” causation test—i.e., that disability-related conduct need only be a motivating factor in the adverse decision. The record showed that school officials removed Gregory based on the precise behaviors they had been warned were disability-related, satisfying the motivating factor test and warranting denial of judgment as a matter of law and of a new trial.

Attorney’s Fees: The ADA authorizes an award of “reasonable attorney’s fees.” The lodestar method—reasonable hours multiplied by reasonable rates—is the default. District courts may apply percentage deductions for inefficiencies, but any cut must be tied to specific, identified overbilling or vague entries and must reflect the plaintiff’s overall success. Here, the district court identified some vague entries and overlapping travel time, but then imposed an 80% across-the-board reduction—an unusually large cut unsupported by the record. The Second Circuit held that fee reductions must be proportionate both to the extent of overbilling and to the plaintiff’s results, including appellate reversals of dismissals and the common facts underlying successful and unsuccessful claims.

Impact

This decision will guide future ADA Title II and Rehabilitation Act cases in two principal ways:

Recognition of Communication Disabilities: Impairments like Tourette’s syndrome and callosum dysgenesis, which interfere with speaking and emotional control, clearly qualify as disabilities under the ADA and the Rehabilitation Act when they substantially limit major life activities.
Limits on Fee Reductions: Fee-award reductions must be justified by precise, documented billing deficiencies and calibrated to the plaintiff’s degree of success. Broad, disproportionate percentage cuts risk reversal.

Complex Concepts Simplified

Major Life Activities: Key day-to-day functions such as speaking, walking, or concentrating; limitations on these activities can establish disability.
Motivating Factor Test: A plaintiff need only show that their protected characteristic (e.g., disability) was one of the reasons for the adverse action, not the sole cause.
Lodestar Method: A fee-calculation approach multiplying reasonable hours by a reasonable hourly rate, subject to adjustments for efficiency and success.
Proportionate Fee Cuts: Adjustments to a lodestar must reflect identified billing issues and the overall results obtained—not arbitrary or sweeping across-the-board percentages.

Conclusion

Spring v. Allegany-Limestone Central School District reaffirms that communication impairments arising from conditions like Tourette’s syndrome may give rise to ADA and Rehabilitation Act protection, and that adverse decisions motivated by disability-related conduct constitute actionable discrimination. It also underscores that district courts must exercise restraint and precision when trimming attorney’s fee claims: reductions must correlate directly to documented inefficiencies and to the plaintiff’s actual success. On remand, the district court will reassess the Springs’ fee application with these guiding principles in mind.