# Eley v. District of Columbia

> Court of Appeals for the D.C. Circuit · July 10, 2015 · 793 F.3d 97

URL: https://www.frixlaw.com/law-library/cases/9809248

## Case

- **Full name:** Wilma ELEY, Appellee v. DISTRICT OF COLUMBIA, Appellant
- **Court:** Court of Appeals for the D.C. Circuit
- **Decided:** July 10, 2015
- **Citations:** 793 F.3d 97; 417 App. D.C. 97; 417 U.S. App. D.C. 97; 2015 U.S. App. LEXIS 11897; 2015 WL 4153874
- **Precedential status:** Published
- **Opinion:** Concurrence by Kavanaugh
- **Judges:** Henderson, Kavanaugh, Randolph
- **Cited by:** 150 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9809248

## How later opinions describe it (automated extraction)

- stating that because fees matrices are generally "somewhat crude," "a fee *15applicant supplements fee matrices with other evidence such as surveys to update the[m]; affidavits reciting the precise fees that attorneys with similar qualifications have received from fee-paying c…
- finding plaintiff had not met the burden of justifying the reasonableness of the rates where her evidence consisted of declaration from Dr. Kavanaugh explaining the LSI Laffey matrix, the lawyer’s affidavit averring that she charged his paying clients the rates found in the LS…
- finding that a district court abused its discretion in relying on the LSI Laffey Matrix to determine' the prevailing market rate in IDEA litigation “absent ... any record evidence, other than the fee applicant’s declaration, demonstrating that IDEA litigation is as complex as …
- concluding that the district court abused its discretion “[b]y concluding that some version of the Laffey matrix is presumptively reasonable, settling on the LSI Laffey [m]atrix[,] and applying it because no evidence was produced disproving that [the] [ ] litigation was suffic…
- stating that it is the movant’s burden “ ‘to produce satisfactory evidence—in addition to [her] attorney’s own affidavits—that [her] requested rates are in line with those prevailing in the community for similar services by lawyers of reasonable comparable skill, experience, a…

## Opinion text

KAVANAUGH, Circuit Judge,
concurring:
I join the Court’s opinion. I would simply add that, in my view, the United States Attorney’s Office Laffey matrix is appropriate for IDEA cases.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9809248. Public record. Not legal advice.
