Spring v. Allegany-Limestone: Recognizing Disability-Related Conduct as Protected Under Title II ADA and the Rehabilitation Act

Introduction

Spring v. Allegany-Limestone Central School District is a Second Circuit decision handed down on April 10, 2025. In this case, 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. The plaintiffs alleged that the school district unlawfully removed their son, Gregory Spring—who suffered from Tourette’s syndrome and callosal dysgenesis—from the basketball team “by reason of” his disability. At trial, a jury found in favor of the Springs. The district court denied the defendants’ post-trial motions and awarded the plaintiffs attorneys’ fees, reducing the requested amount by 80%. On appeal, the Second Circuit affirmed the denial of judgment as a matter of law and new trial, but vacated and remanded the fee award.

Summary of the Judgment

The Court held that Gregory’s neurological conditions—manifesting as involuntary vocal and motor tics, and impairments in processing and verbal expression—satisfied the ADA/Rehabilitation Act definition of “disability” because they substantially limited his major life activity of speaking and communicating.
It endorsed the “motivating factor” causation standard for discrimination under Title II and Section 504, concluding there was legally sufficient evidence that the school district removed Gregory from the team “by reason of” his disability.
The Court affirmed the district court’s denial of the defendants’ motions for judgment as a matter of law and for a new trial.
It determined that the district court abused its discretion in cutting the plaintiffs’ fee request by 80%—an “unusually large” reduction unsupported by the record—and remanded for recalculation.

Analysis

Precedents Cited

B.C. v. Mount Vernon School District (837 F.3d 152 (2d Cir. 2016)) – held the Rehabilitation Act incorporates the ADA’s definition of disability; provided the standard for “physical or mental impairment” and “major life activities.”
Fed. R. Civ. P. 50(a) – governs judgment as a matter of law; setting the bar that a reasonable jury must have a legally sufficient evidentiary basis for its verdict.
Sedor v. Frank (42 F.3d 741 (2d Cir. 1994)) – explained that discrimination “by reason of” disability includes adverse actions motivated by disability-caused conduct.
Gonzalez v. Rite Aid of New York, Inc. (199 F. Supp. 2d 122 (S.D.N.Y. 2002)) – applied Sedor to hold that conduct caused by Tourette’s could not be the basis for adverse employment action.
Hensley v. Eckerhart (461 U.S. 424 (1983)) – established that the “lodestar” method (reasonable hours × reasonable rate) is the starting point for fee awards, with reductions based on degree of success.
McDonald ex rel. Prendergast v. Pension Plan (450 F.3d 91 (2d Cir. 2006)) – confirmed appellate review of fee awards for abuse of discretion and permitted percentage reductions to trim excessive requests.
Raja v. Burns (43 F.4th 80 (2d Cir. 2022)) – cautioned that across-the-board percentage cuts must be proportionate and tied to identifiable deficiencies in the billing record.
Kirsch v. Fleet Street, Ltd. (148 F.3d 149 (2d Cir. 1998)) – held that fee reductions must bear a reasonable relation to the cause of reduction.

Legal Reasoning

The Court began by reviewing Title II’s and Section 504’s antidiscrimination provisions, both prohibiting adverse actions “by reason of” or “solely by reason of” disability. It accepted for purposes of appeal the plaintiffs’ use of the “motivating factor” standard. Under the ADA, an individual is disabled if they have an impairment that “substantially limits” a major life activity, such as speaking or concentrating. Trial testimony established that Gregory’s Tourette’s and callosal dysgenesis caused involuntary tics, impaired his verbal processing, and triggered emotional outbursts—meeting that threshold.

On causation, the record showed that when Gregory’s involuntary tics manifested in profanity and confrontational behavior on the court, Coach Straub removed him from the team. Gregory’s mother had warned school officials that these symptoms were disability-driven and beyond his control. Under Sedor and Gonzalez, adverse decisions motivated by disability-related conduct constitute unlawful discrimination. Because a reasonable jury could conclude that the school district disciplined Gregory for disability-caused behavior, the Court held that judgment as a matter of law was unwarranted and the denial of a new trial was sound.

Turning to attorneys’ fees, the Court applied the lodestar framework but recognized that district courts may apply percentage cuts to eliminate “fat.” It found the district court’s 80% reduction “unusually large” and unjustified: the record revealed only a handful of double-billing and vague entries, all of which the district court had identified by specific line. Moreover, the district court undervalued the plaintiffs’ overall success by ignoring their successful appeal reversing earlier dismissals. Because the degree of reduction must be proportionate to the deficiency or limited success, the Court vacated the fee award and remanded for recalibration.

Impact

Clarifies that Title II and Section 504 protect not only individuals with known disabilities, but also conduct directly caused by those disabilities.
Reaffirms that involuntary speech impediments and tics may substantially limit major life activities (e.g., speaking, communicating) for ADA purposes.
Endorses the “motivating factor” test under Title II and Section 504, ensuring a lower causation standard than “but-for” when disability-related conduct is at issue.
Guides lower courts on attorneys’ fees: percentage reductions must be tailored, explainable, and proportionate to identifiable billing flaws or to the plaintiffs’ relative success.
Signals to public entities that disciplinary actions must account for disability-related behavior and documented accommodations.

Complex Concepts Simplified

“Major Life Activity”: Activities central to daily living—such as speaking, learning, working—protected under the ADA when substantially limited by an impairment.
“Motivating Factor” Standard: An adverse action is discriminatory if the plaintiff’s disability was one of the reasons that prompted the decision, even if not the only one.
“Lodestar” Method: A calculation of reasonable attorneys’ fees by multiplying hours reasonably spent by a reasonable hourly rate, subject to upward or downward adjustments.
“Vacate and Remand”: The appellate court nullifies the lower court’s decision on a discrete issue (here, fee reduction) and sends it back for further proceedings consistent with the higher court’s guidance.

Conclusion

Spring v. Allegany-Limestone is a landmark summary order that underscores the ADA’s broad protection of individuals whose disability manifests in involuntary behavior. The Second Circuit’s ruling confirms that removal or discipline motivated by disability-driven conduct violates Title II and Section 504. Additionally, the opinion offers a nuanced roadmap for fee awards, requiring proportionate and well-explained reductions. Going forward, school districts and other public entities must carefully distinguish between willful misconduct and disability-related behavior and make individualized assessments before imposing sanctions. Finally, plaintiffs who secure partial victories in complex disability litigation can expect appellate courts to guard against disproportionate cuts to their attorneys’ fees.