Spring v. Allegany-Limestone: Motivating-Factor Causation and Recognition of Communication Impairments Under Title II ADA and the Rehabilitation Act

Introduction

In Spring v. Allegany-Limestone Central School District, the Second Circuit addressed whether a student’s Tourette’s syndrome and related neurological conditions constitute a disability under Title II of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, and whether the school district unlawfully discriminated against him “by reason of” that disability. The plaintiffs—Keri Spring (administrator of the estate of Gregory Spring), Eugene Spring, and Julianne Spring—alleged that the school district and its principal removed Gregory from a sports team because of his disability-related behavior. The district court denied the district’s post-trial motions and awarded surviving family members attorney’s fees, which it later reduced by 80%. Both sides appealed. The Second Circuit affirmed the denial of judgment as a matter of law and new trial motion, but vacated the fee reduction and remanded for recalculation.

Key Parties:

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

Date of Decision: April 10, 2025
Court: United States Court of Appeals for the Second Circuit

Summary of the Judgment

The Second Circuit held:

There was sufficient evidence for a reasonable jury to find that Gregory’s Tourette’s syndrome and callosal dysgenesis substantially limited his ability to communicate and constituted a disability under both the ADA and the Rehabilitation Act.
The evidence showed that the school district removed Gregory from the sports team because of his disability-related tics and impulsive verbal responses, satisfying the “motivating factor” causation standard for discrimination.
The district court properly denied the school district’s post-trial motions for judgment as a matter of law and for a new trial.
However, the district court’s 80% across-the-board reduction of the plaintiffs’ attorney’s fee award was an abuse of discretion: the record did not justify such a steep cut, and the court had sufficient detail to make a proportionate adjustment. The fee award was vacated and remanded for recalculation.

Analysis

1. Precedents Cited

The court relied on and discussed several precedents that shaped its decision:

42 U.S.C. § 12102(1) (ADA definition of “disability”), and 29 U.S.C. § 794(a) (Rehabilitation Act’s incorporation of ADA’s definition).
B.C. v. Mount Vernon Sch. Dist., 837 F.3d 152 (2d Cir. 2016): Confirming that the Rehabilitation Act uses the ADA’s disability definition.
Fed. R. Civ. P. 50(a): Procedural standard for judgment as a matter of law (“no reasonable jury could find for the non-movant”).
Sedor v. Frank, 42 F.3d 741 (2d Cir. 1994): Holding that conduct caused by a disability may itself establish causation for discrimination.
Natofsky v. City of New York, 921 F.3d 337 (2d Cir. 2019) (discussed but not adopted here): Distinguished Title I “but-for” causation from Title II’s “motivating factor” approach.
McDonald ex rel. Prendergast v. Pension Plan, 450 F.3d 91 (2d Cir. 2006) and Hensley v. Eckerhart, 461 U.S. 424 (1983): Lodestar method and standards for attorney’s fee awards.
Raja v. Burns, 43 F.4th 80 (2d Cir. 2022): Permissible scope and proportionality of fee reductions for vague or duplicative time entries.

2. Legal Reasoning

The court’s reasoning unfolded in two parts:

Disability and Discrimination: Trial testimony demonstrated that Gregory’s Tourette’s syndrome and callosal dysgenesis caused involuntary tics, repetitive profanity, impaired speech processing, anxiety, and impulsive outbursts. These substantially limited his major life activity of communication under the ADA and Rehabilitation Act. The coach’s admission that Gregory’s removal from the team turned on “what he said” and “the way he acted” after being kicked—along with prior notice of Gregory’s condition by his mother—supported a finding that the disability was a “motivating factor” in the adverse decision.
Attorney’s Fees: Under 42 U.S.C. § 12205, a prevailing plaintiff is entitled to reasonable attorney’s fees. Although the district court identified duplicative billing for travel time and some vague entries, it had sufficient detail to excise those specific items rather than impose an 80% across-the-board reduction. Nor did the district court account fully for the plaintiffs’ appellate victory reversing earlier dismissals. In these circumstances, an extreme percentage cut was disproportionate to the billing deficiencies and the degree of success.

3. Impact on Future Cases

This decision clarifies and reinforces several points of significance:

Conditions that cause involuntary speech disruptions and emotional outbursts—such as Tourette’s syndrome—may qualify as disabilities under Title II ADA and the Rehabilitation Act when they substantially limit communication.
Courts in Title II and Rehabilitation Act cases may apply a “motivating factor” causation test for discrimination, distinguishing it from Title I’s stricter “but-for” standard.
When awarding fees under civil rights statutes, district courts must tailor reductions to identifiable billing flaws and the plaintiff’s relative success, avoiding unduly punitive percentage cuts based on generalized impressions.

Complex Concepts Simplified

“Substantially limits a major life activity”: A person has a disability if an impairment makes a core task—like speaking or concentrating—significantly harder than for most people.
“Motivating factor” test: Under Title II ADA and the Rehabilitation Act, a plaintiff need only show that the disability played a part—even if not the sole cause—in the defendant’s decision to take adverse action.
“Lodestar method”: A way to calculate attorney’s fees by multiplying reasonable hours worked by a reasonable hourly rate, subject to adjustments for success and billing quality.
“Judgment as a matter of law” (Rule 50): The court may set aside a jury verdict if no reasonable jury could have found for the non-moving party based on the evidence presented.

Conclusion

Spring v. Allegany-Limestone establishes that neurological conditions causing involuntary speech and emotional dysregulation may be disabilities under the ADA and the Rehabilitation Act when they substantially limit major life activities such as communication. It confirms that discrimination “by reason of” a disability requires only that the disability be a motivating factor in the adverse decision. Finally, the case underscores the need for proportionality in attorney’s fee awards—district courts must tie reductions to concrete deficiencies and the actual scope of the plaintiff’s success. On remand, the district court must recalculate fees in light of these principles.