Accordingly, we reverse the district court as to that order and remand. We review three district court orders: Blackman v. District of Columbia, 328 F.Supp.2d 36 (D.D.C. 2004), Chavez v. District of Columbia, 328 F.Supp.2d 21 (D.D.C. 2004), and Watkins v. Vance, 328 F.Supp.2d 27 (D.D.C. 2004), in which order the district court granted the attorney's fees petitions in both Watkins v. Vance, No. 98-cv-3081 and Rice v. Vance, No. 00-cv-0330. Notices of appeal were filed in all four cases. Between the district court orders and the notices of appeal, Clifford Janey replaced Paul Vance as CEO/Superintendent of the District of Columbia Public Schools and as defendant in Watkins v. Vance (now Watkins v. Janey) and Rice v. Vance (now Rice v. Janey).
While the administrative case and the injunction proceedings both involved the subject of proper placement for K.S., the Court finds that the matters encompassed by the injunction were more like a new, separate lawsuit involving different placement facilities and different clinical needs based on changes in the severity of K.S.'s condition—these issues were not inextricably intertwined with those upon which Plaintiffs prevailed at the administrative level. See Watkins v. Vance, 328 F. Supp. 2d 27, 34 (D.D.C. 2004) ("Plaintiffs have not offered any reason, however, why efforts related to the child's new placement . . . should be compensated; plaintiffs do not tie these efforts to any court order or otherwise demonstrate a basis for payment of fees."); cf. Douglas v. D.C., 67 F. Supp. 3d 36, 42 (D.D.C. 2014) (awarding fees for injunctive relief where motion for injunction resulted in "stay-put" order and was premised on the same allegations and requested the same relief sought in IDEA complaint); Neisz v. Portland Pub. Sch. Dist., 684 F. Supp. 1530, 1533 (D. Or. 1988) (awarding fees for time expended seeking a temporary restraining order even though the injunctive relief sought was not granted where pursuit of the injunctive relief in federal court was instrumental in student's success during administrative hearings). Further, Plaintiffs did not prevail on their request for injunctive relief.
Pl.'s Reply to Def.'s Resp. to Pl.'s Objs. 4, ECF No. 19. Courts may award fees related to implementing or enforcing a decision or order. SeeDouglas v. District of Columbia, 67 F.Supp.3d 36, 44 (D.D.C. 2014) (concluding that entries related to implementing the court's stay-put order were reasonable and recoverable); Blackman v. District of Columbia, 390 F.Supp.2d 16, 20 (D.D.C. 2005) ("A district court may award fees to a prevailing party for reasonable postjudgment monitoring" of the losing party's compliance with the terms of the judgment."); Watkins v. Vance, 328 F.Supp.2d 27, 33 (D.D.C. 2004) ("The Court concludes that plaintiffs' counsel's efforts in scheduling a timely IEP meeting, especially in light of defendants' failures to provide Kenneth an adequate IEP in the first place, are recoverable because the effort was the direct result of a court order."). Plaintiff has shown that entries related to implementing/enforcing the Hearing Officer's determination that J.S. was denied a FAPE are compensable and were properly billed.
Once a plaintiff has provided detailed billing records and invoices, a "presumption arises [in plaintiff's favor] that the number of hours billed is reasonable[,] and the burden shifts to the defendant to rebut the plaintiff's showing of reasonable hours." Watkins v. Vance, 328 F. Supp. 2d 27, 31 (D.D.C. 2004); see Baker, 815 F. Supp. 2d at 107; In re InPhonic, Inc., 674 F. Supp. 2d at 280; Herbin v. District of Columbia, No. 02-1185, 2006 WL 890673, at *5 (D.D.C. Apr. 4, 2006). A party objecting to the requested amount of attorneys' fees must justify an adjustment of the lodestar and "submit facts and detailed affidavits to show why the applicant's request should be reduced or denied."
Once a plaintiff has provided detailed billing records and invoices, a “presumption arises [in plaintiff's favor] that the number of hours billed is reasonable[,] and the burden shifts to the defendant to rebut the plaintiff's showing of reasonable hours.” Watkins v. Vance, 328 F.Supp.2d 27, 31 (D.D.C.2004); seeBaker, 815 F.Supp.2d at 107; In re InPhonic, Inc., 674 F.Supp.2d at 280; Herbin v. District of Columbia, No. 02–1185, 2006 WL 890673, at *5 (D.D.C. Apr. 4, 2006). A party objecting to the requested amount of attorneys' fees must justify an adjustment of the lodestar and “submit facts and detailed affidavits to show why the applicant's request should be reduced or denied.”
Considering the District's previous efforts to exclude Mr. Douglas from attending Dunbar and transfer him to another school, the Court concludes that these entries are reasonable and recoverable. SeeWatkins v. Vance, 328 F.Supp.2d 27, 33–34 (D.D.C.2004) (ordering attorneys' fees and costs under the IDEA for work done after a court order where “the effort was the direct result of a court order”). Although the District failed to raise the issue, Mr. Douglas' attorneys' fees relating to travel will be compensated at half the above indicated hourly rate. SeeCooper v. United States R.R. Retirement Bd., 24 F.3d 1414, 1417 (D.C.Cir.1994) (allowing fees for travel time at half the attorney's hourly rate); Doe v. Rumsfeld, 501 F.Supp.2d 186, 193 (D.D.C.2007) (same).
Accordingly, the Court's award of attorneys' fees for Plaintiffs' success in securing an enforcement Order from this Court is made pursuant to 42 U.S.C. § 1988. See Watkins v. Vance, 328 F. Supp. 2d 27, 33 (D.D.C. 2004) (finding that in an action to enforce rights under the IDEA, an award of attorneys' fees can be made under section 1988). The standard for assessing whether a litigant is a "prevailing party," and whether an award of fees is reasonable, is "generally applicable in all cases in which Congress has authorized an award of fees to a `prevailing party.'"
Defendants as the moving parties have the burden to submit supporting documentation with their fee motion that provides "sufficient detail so that the Court can determine `with a high degree of certainty' that the hours billed were actually and reasonably expended." Hiram C. v. Manteca Unified Sch. Dist., 2004 WL 4999156, *2 (E.D. Cal. Nov. 5, 2004) (quoting Watkins v. Vance, 328 F. Supp. 2d 27, 31 (D.C. 2004)). Courts "frow[n] on block billing where discrete and unrelated tasks are lumped into one entry, as the practice can make it impossible . . . to determine the reasonableness of the hours spent on each task." Defenbaugh v. JBC Assocs., Inc., 2004 WL 1874978, *9 (N.D. Cal. Aug. 10, 2004).
When the requested hourly rates are higher than those set forth in the Laffey Matrix, courts generally reduce the attorneys' hourly rates to the rates provided by the Laffey Matrix. See e.g. Dist. of Columbia v. R.R., 390 F. Supp. 2d 38, 41 (D.D.C. 2005); see e.g. Watkins v. Vance, 328 F. Supp. 2d 27, 31 n. 3 (D.D.C. 2004). Accordingly, the court reduces Iseman's rate for work performed from June 1, 2004 to May 31, 2005 to $225 per hour and her rate for work performed from June 1, 2005 to May 31, 2006 to $235 per hour.