Spring v. Allegany-Limestone Central School District: Recognizing Disability-Linked Conduct Under Title II of the ADA and Curbing Excessive Fee Awards

Introduction

In Spring v. Allegany-Limestone Central School District (2d Cir. Apr. 10, 2025), the United States Court of Appeals for the Second Circuit considered two main questions: (1) whether a student’s Tourette’s‐related speech and behavioral tics qualified as a “disability” under Title II of the Americans with Disabilities Act (“ADA”) and the Rehabilitation Act, and if so, whether removal from a sports team “by reason of” those tics constituted unlawful discrimination; and (2) whether the district court abused its discretion by slashing plaintiffs’ attorney’s fees by 80%. The case arose after the Allegany-Limestone Central School District and its principal, Kevin Straub, removed student Gregory Spring from a lacrosse team following an on-field incident in which he kicked another player and uttered a profanity—behaviors intrinsically connected to his neurological conditions. Plaintiffs-appellees Keri, Eugene and Julianne Spring, as Gregory’s estate representatives, obtained a favorable jury verdict. The school district appealed the denial of judgment as a matter of law and new trial; the Springs cross-appealed the reduction of attorney’s fees.

Summary of the Judgment

• The Second Circuit affirmed the jury’s finding that Gregory’s Tourette’s and callosal dysgenesis substantially limited his ability to communicate, making him “disabled” under 42 U.S.C. § 12102 and 29 U.S.C. § 794(a).
• The court held there was more than sufficient evidence for a jury to conclude that the removal from the lacrosse team was motivated by Gregory’s disability-related conduct, in violation of Title II of the ADA and the Rehabilitation Act.
• The panel vacated and remanded the district court’s 80% reduction of the Springs’ attorney’s fees, finding that the extent of the cut was disproportionate to the billing deficiencies identified and to the degree of success the plaintiffs actually achieved.

Analysis

Precedents Cited

1. ADA and Rehabilitation Act Definitions
The court relied on 42 U.S.C. § 12102’s definition of “disability”—an impairment that “substantially limits one or more major life activities”—and on 29 U.S.C. § 794(a)’s incorporation of that definition for curricula or activities receiving federal funds.

2. B.C. v. Mount Vernon School District (2d Cir. 2016)
Clarified that the Rehabilitation Act uses the ADA’s disability definition and recognized “major life activities” to include speaking and communicating.

3. Sedor v. Frank (2d Cir. 1994)
Held that discrimination can be established when disability “caused conduct that, in turn, motivated” the adverse action.

4. Natofsky v. City of New York (2d Cir. 2019)
Though not controlling on Title II, it provides context for “but-for” versus “motivating factor” causation tests in ADA Title I cases.

5. Hensley v. Eckerhart (U.S. 1983) and McDonald ex rel. Prendergast (2d Cir. 2006)
Established standards for the lodestar method and the district court’s discretion in trimming attorney’s fees via percentage reductions.

Legal Reasoning

● Disability Finding
Trial testimony detailed Gregory’s Tourette’s tics, including involuntary profanity (“the ‘f’ word”), verbal repetitions, processing delays, impulsive outbursts and emotional dysregulation. A reasonable jury could conclude these impairments substantially limited his ability to communicate—a major life activity—particularly in stressful or authoritative settings.

● Discrimination by Reason of Disability
The coach and principal admitted on cross-examination that they removed Gregory from the team for his words and demeanor. Plaintiffs had provided prior notice in Gregory’s IEP meetings about his propensity for uncontrollable language when under stress. Under Sedor, a nexus between disability-triggered conduct and adverse action sufficed to establish motivating-factor causation.

● Fee Award Remand
The district court identified double‐billing and some vague time entries but then applied a blanket 80% reduction. The Second Circuit held that (i) the record showed specific billing errors that could be excised individually, and (ii) plaintiffs’ partial procedural victory on appeal—reversing earlier dismissals—enhanced their overall success. A cut of that magnitude was thus disproportionate.

Impact on Future Cases

• School districts and other public entities must recognize that disability-linked behavioral outbursts (e.g., Tourette’s profanity tics) can qualify as a protected impairment under Title II and the Rehabilitation Act.
• Decisions driven by a student’s disability symptoms—rather than neutral, disciplinary infractions—are subject to strict review for discriminatory motive.
• Courts reviewing fee applications will demand a granular approach to billing reductions and evaluate the plaintiff’s total success, including appellate victories, to calibrate any percentage cut against the identified deficiencies.

Complex Concepts Simplified

“Substantially limits”: An impairment must make a basic life activity—like speaking—difficult on a routine basis.

“Motivating factor”: The plaintiff need only show the disability-related conduct influenced the decision, not that it was the sole cause. Under the ADA’s Title II and the Rehabilitation Act, this lower causation bar applies.

Lodestar Method: The starting point for fee awards is the reasonable rate × hours worked. Courts may then trim or enhance it to reflect the quality of representation and the degree of success.

Conclusion

Spring v. Allegany-Limestone clarifies that behavior directly stemming from a neurological disability—such as Tourette’s-related tics—is entitled to ADA and Rehabilitation Act protections when it substantially limits communication. Public entities must tailor their disciplinary actions to account for disability-linked conduct. The decision also reaffirms that courts must apply percentage reductions to attorney’s fees judiciously, ensuring any cut aligns with specific billing deficiencies and the overall success achieved by the prevailing party.