Spring v. Allegany-Limestone Central School District: Proportionality in ADA Attorney’s Fees and Disability Determinations

I. Introduction

Spring v. Allegany-Limestone Central School District is a summary order issued by the United States Court of Appeals for the Second Circuit on April 10, 2025. The case arises from the removal of a high-school student, Gregory Spring, from his school’s football team after an incident in which he used profanity and displayed impulsive conduct linked to his neurological conditions—Tourette’s syndrome and callosal dysgenesis. The student’s administrator and family (the “Springs”) sued the school district, its board of education, and the principal (collectively “Allegany-Limestone”) under Title II of the Americans with Disabilities Act (“ADA”) and Section 504 of the Rehabilitation Act, alleging unlawful discrimination “by reason of” Gregory’s disability.

Following a jury verdict in favor of the Springs, Allegany-Limestone moved for judgment as a matter of law (“JMOL”) or a new trial, challenging both (1) the sufficiency of the evidence that Gregory was disabled under the ADA and Rehabilitation Act and (2) the finding that his removal was motivated by discriminatory animus. The Springs cross-appealed the district court’s post-judgment reduction of their attorneys’ fees by 80%. The Second Circuit affirmed the denial of JMOL and a new trial, but vacated and remanded the fee award, establishing guiding principles on proportional fee reductions and reaffirming evidentiary standards under the ADA and Rehabilitation Act.

II. Summary of the Judgment

The Second Circuit issued a summary order with the following holdings:

1. On the ADA and Rehabilitation Act claims, the court held that there was legally sufficient evidence for a reasonable jury to find that:
   • Gregory Spring’s Tourette’s syndrome and callosal dysgenesis substantially limited his major life activity of communication;
   • Allegany-Limestone knew of his disabilities and removed him from the team “by reason of” his disability (applying the “motivating factor” standard for Title II and Section 504).
2. The court affirmed the district court’s denial of JMOL under Federal Rule of Civil Procedure 50 and denial of a new trial under Rule 59.
3. On the fee application under 42 U.S.C. § 12205, the court held that an 80% across-the-board cut of the lodestar award was excessive. Although some time entries were vague and there were duplications, the court found that the deficiencies identified by the district court did not justify such a steep reduction. The court vacated the fee award and remanded for a proportionate adjustment consistent with Second Circuit precedent.

III. Analysis

1. Precedents Cited

The Second Circuit relied on a number of controlling decisions to frame its analysis:

• Palin v. New York Times Co. (113 F.4th 245, 263 (2d Cir. 2024)) – Standard of review for JMOL under Rule 50(a).
• 42 U.S.C. § 12132 and 29 U.S.C. § 794(a) – Statutory texts of Title II of the ADA and Section 504 of the Rehabilitation Act.
• B.C. v. Mount Vernon School District (837 F.3d 152 (2d Cir. 2016)) – Definition of “disability” under the Rehabilitation Act, incorporating ADA’s terms.
• Sedor v. Frank (42 F.3d 741 (2d Cir. 1994)) – Causation principle: a disability-related act can itself motivate discrimination.
• Hensley v. Eckerhart (461 U.S. 424 (1983)) – Lodestar method and burden on fee applicant to document hours and rates.
• McDonald ex rel Prendergast v. Pension Plan (450 F.3d 91 (2d Cir. 2006)) – Standard of review for fee awards and recognition of percentage deductions to trim excess.
• Raja v. Burns (43 F.4th 80 (2d Cir. 2022)) – Limits on percentage cuts; reductions must be proportionate to the deficiencies identified.
• Kirsch v. Fleet Street, Ltd. (148 F.3d 149 (2d Cir. 1998)) – Reasonable percentage deduction concept for fee trimming.

2. Legal Reasoning

a. Disability Determination. The court observed testimony that Gregory’s Tourette’s and callosal dysgenesis:

• Caused vocal tics—including involuntary profanity—that interfered with his ability to speak and be understood;
• Resulted in impulsive verbal outbursts and emotional dysregulation when he felt pressured by authority;
• Substantially limited the major life activity of communication under 42 U.S.C. § 12102(1), as recognized in Wright v. Memphis Light, Gas & Water Div. (558 F. App’x 548, 550 (6th Cir. 2014)).

b. Causation and Discrimination. The “motivating factor” standard under Title II and Section 504 requires only that the protected characteristic (disability) be a driving reason for the adverse action. The coach and administrators admitted they removed Gregory for “what he said” and “the way he acted,” despite advance notice from Gregory’s mother and his IEP documentation warning that such conduct stemmed from his disability. Under Second Circuit law, conduct arising from a disability may itself trigger discriminatory treatment (Sedor v. Frank).

c. Attorney’s Fees. The court applied the lodestar framework (Hensley) but recognized that courts can use a percentage deduction to address over-billing (McDonald). The district court had reduced an $451,688.92 lodestar by 80%, leaving $90,337.79. The Second Circuit found this cut disproportionate because:

• The district court could identify only limited duplications and vague entries, not a wholesale “billing morass.”
• The degree of the Springs’ success—reversal of certain dismissals on appeal plus a full trial verdict on disability discrimination—was substantially higher than the district court’s narrative suggested.
• The court’s citation to Raja and Kirsch demanded a “reasonable percentage” deduction calibrated to specific flaws rather than a fixed, large cutoff.

The Second Circuit thus vacated and remanded for a proportionate fee determination.

3. Impact

This decision clarifies two important points for future ADA and Rehabilitation Act litigation:

1. Evidence of Disability and Causation. Courts reviewing JMOL or new-trial motions must credit a plaintiff’s uncontroverted testimony about neurological or mental impairments that substantially limit major life activities, and recognize that disciplinary actions responding to disability-related conduct can constitute discrimination under Title II and Section 504.
2. Proportional Fee Reductions. In fee-shifting cases, large across-the-board cuts (e.g., 80%) are subject to heightened scrutiny. Fee awards must be trimmed in proportion to identified billing deficiencies and should reflect the relative success a plaintiff achieved on all claims, including successful appeals and trial victories.

IV. Complex Concepts Simplified

• Title II of the ADA prohibits discrimination by public entities on the basis of disability, requiring reasonable modifications and forbidding adverse actions “by reason of” disability.
• Rehabilitation Act § 504 applies to any program receiving federal funds and forbids discrimination “solely by reason of” disability, using the ADA’s definition of “disability.”
• Major Life Activities include tasks such as speaking, concentrating, walking, and learning. An impairment that substantially limits any of these qualifies as a disability.
• Jurisdictional Motions (Fed. R. Civ. P. 50 & 59) – Rule 50(a) (JMOL) tests whether a reasonable jury could find for the nonmoving party; Rule 59(a) tests whether a verdict is “against the weight of the evidence” or would result in a “miscarriage of justice.”
• Lodestar Method – A two-step process for awarding fees: multiply hours reasonably expended by a reasonable hourly rate, then adjust for factors such as success, complexity, and efficiency.
• Percentage Deduction – A practical tool to remove wasteful or duplicative billing, but it must be applied in proportion to identified deficiencies—not as a blanket discount.

V. Conclusion

Spring v. Allegany-Limestone reaffirms that summary judgments and post-trial motions in ADA and Rehabilitation Act cases must credit evidence of disability-related impairments that substantially limit major life activities. It also sets guardrails on fee awards, emphasizing proportionality and focused reductions rather than flat, excessive cuts. Together, these principles will guide trial and appellate courts in evaluating both the merits of disability discrimination claims and the reasonableness of fee petitions under federal civil rights statutes.