School Bd. of Prince William County v. Malone

Citations: 662 F. Supp. 999; 40 Educ. L. Rep. 761; 1987 U.S. Dist. LEXIS 9762Docket: Civ. Action 83-862-A

Court: District Court, E.D. Virginia; March 10, 1987; Federal District Court

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The United States District Court for the Eastern District of Virginia addressed the issue of attorneys' fees following a remand from the Court of Appeals in the case of School Board of the County of Prince William v. Jerry F. Malone. The Court of Appeals had affirmed the district court's judgment on May 24, 1985, and subsequently awarded costs on June 14, 1985. The defendants filed an application for attorneys' fees on November 6, 1986, prompted by a new amendment to the Education of the Handicapped Act allowing courts to award reasonable attorneys' fees to prevailing parents in relevant cases pending as of July 4, 1984. The School Board contested the application on several grounds, including constitutional arguments regarding retroactive application and spending power, as well as issues of timeliness and documentation.

The court concluded that the retroactive application of the amendment does not violate the separation of powers because it does not prescribe a specific rule of decision in this case, which had already been decided. The court also determined that the retroactive application does not exceed Congress's spending power, asserting that it relates to the timing of cost assessments in federal litigation rather than imposing new liabilities. Regarding timeliness, the School Board cited local and federal rules requiring requests for fees to be made promptly following the final judgment, but the court did not find these arguments sufficiently compelling to deny the application for fees.

The time limits for filing applications under the Education for All Handicapped Children Act (EHA) had expired prior to the August 5, 1986 amendment. The defendants filed their application three months post-amendment, which the court deemed timely, noting that it is unreasonable to expect immediate awareness of legislative changes. The court addressed objections to the claim for attorneys' fees regarding administrative proceedings, clarifying that the amendment's wording includes both administrative and civil actions, as supported by legislative history. The defendants provided a detailed account of tasks performed and hours worked, which the court found reasonable, establishing a presumptively reasonable attorney's fee of $11,770.00 based on a $100 hourly rate. The 1986 amendment grants the court discretion in awarding fees, and the court determined that despite the timing of the application, it should award fees due to the defendants’ success at the administrative level and the lack of exceptional circumstances against such an award. Consequently, the court ordered the plaintiff to pay the defendants $11,770.00 in attorneys' fees.

The County's argument in its rebuttal claims that the retroactive application of the legislation violates the Due Process Clause. However, this argument is deemed ineffective in light of the precedent established in Pension Benefit Guaranty Corp. v. R.A. Gray Co., which supports the rational legislative purpose behind such application. The document also outlines the constraints on Congress's power to impose conditions on States through its spending power, citing several cases including Steward Machine Co. v. Davis and Lau v. Nichols. Notably, in National League of Cities v. Usery, a congressional enactment was struck down, but this limitation was not cited as the ruling's basis, and this decision has since been overruled by Garcia v. San Antonio Metro. Transit Auth. Ultimately, the document concludes that any limitations on the spending power have not been surpassed in this instance.