Spring v. Allegany-Limestone Central School District: Affirming the Motivating-Factor Test and Constraining ADA Fee Reductions

Introduction

Spring v. Allegany-Limestone Central School District is a Second Circuit summary order decided on April 10, 2025. The case arises from the removal of high-school student Gregory Spring from his football team after he displayed uncontrollable verbal tics and uttered profanity—symptoms of Tourette’s syndrome and callosal dysgenesis—during a practice incident. Gregory’s surviving family (Keri, Eugene, and Julianne Spring) sued Allegany-Limestone Central School District, its Board of Education, and Principal Kevin Straub under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, alleging that the District discriminated against Gregory “by reason of” his disability. At trial, a jury found that the District had indeed discriminated and awarded damages. On appeal, the District challenged (1) the sufficiency of the evidence on disability and discrimination, and (2) the post-trial denial of judgment as a matter of law and new-trial motion. The Springs cross-appealed the district court’s 80% reduction of their attorney’s fees.

Summary of the Judgment

The Second Circuit issued three rulings:

1. Denial of Judgment as a Matter of Law & New Trial: The court affirmed the district court’s denial of the District’s post-trial motions. It held that the evidence was legally sufficient for a reasonable jury to conclude that:
   • Gregory Spring’s Tourette’s syndrome and callosal dysgenesis substantially limited his ability to speak and communicate;
   • His on-field outburst and verbal tics were manifestations of that disability;
   • The District removed him from the team “by reason of” those disability-related behaviors, satisfying the ADA’s motivating-factor standard.
2. Motivating-Factor Standard: Assuming—without deciding—that Title II and Section 504 permit a “motivating factor” causation test, the court found no error in leaving this question and evidence to the jury.
3. Attorney’s Fees Award: The court vacated the district court’s 80% across-the-board cut of the Springs’ requested fees and remanded for a more proportional analysis. It held that:
   • The reductions did not track the degree of success or the nature of any billing deficiencies;
   • The district court had identified specific travel duplications and vague entries, but its extreme 80% cut went well beyond a permissible “reasonable percentage” reduction.

Analysis

Precedents Cited

• Palin v. New York Times Co. (113 F.4th 245): Standards for reviewing Rule 50 motions (judgment as a matter of law) de novo, construing all facts in the non-movant’s favor.
• B.C. v. Mount Vernon School District (837 F.3d 152): The Rehabilitation Act incorporates the ADA’s definition of “disability.”
• Sedor v. Frank (42 F.3d 741): Causation under the ADA can be established if the disability caused conduct that motivated an adverse decision.
• Qorrolli v. Metropolitan Dental Associates (124 F.4th 115): Standards for granting new trials.
• McDonald ex rel. Prendergast v. Pension Plan (450 F.3d 91): Lodestar method and discretion to trim fees via percentage deductions.
• Raja v. Burns (43 F.4th 80): Fee reductions must be proportionate to the deficiencies and degree of success; courts cannot make extreme cuts absent clear record support.
• Green v. Torres (361 F.3d 96): Common-core doctrine—successful and unsuccessful claims sharing facts may justify fees for all work.
• Spring v. Allegany-Limestone Cent. Sch. Dist. (655 F. App’x 25, 2016): Earlier summary order reversing dismissal of the ADA/Rehab Act claims on threshold standing and causation grounds.

Legal Reasoning

1. Disability and Discrimination: Title II of the ADA (42 U.S.C. § 12132) and Section 504 of the Rehabilitation Act (29 U.S.C. § 794(a)) prohibit public entities and federally funded programs from discriminating against individuals “by reason of” or “solely by reason of” physical or mental impairments that substantially limit major life activities. “Major life activities” include speaking and communicating. The court had no difficulty finding:

• Testimony that Gregory’s Tourette’s and callosal dysgenesis caused uncontrollable verbal outbursts, repetition of profanity, and emotional dysregulation;
• Evidence that these impairments substantially limited his ability to process and articulate speech;
• A direct link between those disability-related behaviors and the school’s decision to remove him from the team.

Under Sedor, causation may rest on the fact that the conduct leading to discipline was itself a manifestation of the plaintiff’s disability. The Circuit thus affirmed denial of judgment as a matter of law under Federal Rule 50 and rejection of a new trial.

2. Attorney’s Fees: The ADA entitles the “prevailing party” to “reasonable attorney’s fees.” Courts begin with the “lodestar” (hours × reasonable rate) and then may adjust. Percentage-of-reduction methods are “practical means of trimming fat,” but reductions must bear a rational relationship to:

• The plaintiff’s overall success (Hensley v. Eckerhart);
• Identifiable billing deficiencies (double billing, vagueness, block entries).

Here, the district court acknowledged significant pre-trial dismissals but overlooked the Springs’ successful cross-appeal in 2016 and failed to credit the common core of work that supported both successful and unsuccessful claims. Nor did its opinion identify a principled basis for an 80% cut—an “unusually large” reduction that ran afoul of Second Circuit precedent (Raja, Kirsch).

Impact

Spring v. Allegany-Limestone offers several lessons for ADA and Rehabilitation Act litigation:

• “Disability as Cause”Theory: Reaffirms that disability-related manifestations (verbal tics, outbursts) can satisfy both the impairment and causation elements of a discrimination claim.
• Motivating-Factor Approach: Confirms (for Title II/Section 504) that a motivating-factor standard is viable, and the question is typically for the jury unless no reasonable juror could find causation.
• Fee-Shifting Discipline: Emphasizes proportionality—courts must tie reductions to specific billing excesses or degrees of success, not simply impose arbitrary percentage cuts.
• Precedential Effect: Although this is a summary order, its reasoning on fee awards will guide district judges in Civil Rights Act and ADA fee applications, encouraging detailed time records and careful exercise of discretion in lodestar adjustments.

Complex Concepts Simplified

• Judgment as a Matter of Law (Rule 50): A post-verdict motion asking the court to overturn the jury’s decision because no legally sufficient evidence supports it.
• New Trial Motion (Rule 59): A request to set aside the verdict and order a fresh trial, typically based on errors in procedure or against the weight of the evidence.
• Lodestar Method: A fee-shifting calculation multiplying reasonable hours by a reasonable hourly rate, subject to adjustments.
• Motivating-Factor vs. But-For Causation: “Motivating factor” requires showing that disability was one of the reasons for adverse action; “but-for” demands it be the sole cause. This case assumes the motivating-factor standard for Title II and Section 504.
• Common-Core Doctrine: When successful and unsuccessful claims share facts, fee awards may include work on both, reflecting the interrelated nature of litigation.

Conclusion

Spring v. Allegany-Limestone stands as a useful reaffirmation of key ADA principles: it confirms that physical and mental impairments manifesting as uncontrollable speech and emotional reactions can establish disability and causation under Title II and the Rehabilitation Act. Equally important, it constrains district courts in attorney-fee deliberations, demanding proportional, well-supported reductions rather than arbitrary cuts. Taken together, the Second Circuit’s decision sharpens both substantive discrimination law and the procedural discipline of fee awards in civil rights litigation.