Haywood v. LRA Corporation et al

Filing 29

MOTION by Plaintiff Sarah Jean Haywood for judgment (Attachments: # 1 Exhibit A-Affidavit of Plaintiff, # 2 Exhibit B-Summary of Attorney's Fees, # 3 Exhibit C-Laffey Matrix, # 4 Exhibit D-Consumer Law Attorney Fee Survey)(Marco, David)

EXHIBIT C

LAFFEY MATRIX -- 2003-2013
(2009-10 rates were unchanged from 2008-09 rates)
Years (Rate for June 1 - May 31, based on prior year's CPI-U)
Experience

03-04

04-05

05-06

06-07

07-08

08-09

09-10

10-11

11-12

12-13

20+ years

380

390

405

425

440

465

465

475

495

505

11-19 years

335

345

360

375

390

410

410

420

435

445

8-10 years

270

280

290

305

315

330

330

335

350

355

4-7 years

220

225

235

245

255

270

270

275

285

290

1-3 years

180

185

195

205

215

225

225

230

240

245

Paralegals &
Law Clerks

105

110

115

120

125

130

130

135

140

145

Explanatory Notes:
1.

This matrix of hourly rates for attorneys of varying experience levels and paralegals/law clerks has been
prepared by the Civil Division of the United States Attorney's Office for the District of Columbia. The matrix is
intended to be used in cases in which a "fee-shifting" statute permits the prevailing party to recover "reasonable"
attorney's fees. See, e.g., 42 U.S.C. § 2000e-5(k) (Title VII of the 1964 Civil Rights Act); 5 U.S.C. §
552(a)(4)(E) (Freedom of Information Act); 28 U.S.C. § 2412 (b) (Equal Access to Justice Act). The matrix
does not apply in cases in which the hourly rate is limited by statute. See 28 U.S.C. § 2412(d).

2.

This matrix is based on the hourly rates allowed by the District Court in Laffey v. Northwest Airlines, Inc., 572
F. Supp. 354 (D.D.C. 1983), aff'd in part, rev'd in part on other grounds, 746 F.2d 4 (D.C. Cir. 1984), cert.
denied, 472 U.S. 1021 (1985). It is commonly referred to by attorneys and federal judges in the District of
Columbia as the "Laffey Matrix" or the "United States Attorney's Office Matrix." The column headed
"Experience" refers to the years following the attorney's graduation from law school. The various "brackets" are
intended to correspond to "junior associates" (1-3 years after law school graduation), "senior associates" (4-7
years), "experienced federal court litigators" (8-10 and 11-19 years), and "very experienced federal court
litigators" (20 years or more). See Laffey, 572 F. Supp. at 371.

3.

The hourly rates approved by the District Court in Laffey were for work done principally in 1981-82. The
Matrix begins with those rates. See Laffey, 572 F. Supp. at 371 (attorney rates) & 386 n.74 (paralegal and law
clerk rate). The rates for subsequent yearly periods were determined by adding the change in the cost of living
for the Washington, D.C. area to the applicable rate for the prior year, and then rounding to the nearest multiple
of $5 (up if within $3 of the next multiple of $5). The result is subject to adjustment if appropriate to ensure that
the relationship between the highest rate and the lower rates remains reasonably constant. Changes in the cost
of living are measured by the Consumer Price Index for All Urban Consumers (CPI-U) for WashingtonBaltimore, DC-MD-VA-WV, as announced by the Bureau of Labor Statistics for May of each year.

4.

Use of an updated Laffey Matrix was implicitly endorsed by the Court of Appeals in Save Our Cumberland
Mountains v. Hodel, 857 F.2d 1516, 1525 (D.C. Cir. 1988) (en banc). The Court of Appeals subsequently
stated that parties may rely on the updated Laffey Matrix prepared by the United States Attorney's Office as
evidence of prevailing market rates for litigation counsel in the Washington, D.C. area. See Covington v.
District of Columbia, 57 F.3d 1101, 1105 & n. 14, 1109 (D.C. Cir. 1995), cert. denied, 516 U.S. 1115 (1996).
Lower federal courts in the District of Columbia have used this updated Laffey Matrix when determining
whether fee awards under fee-shifting statutes are reasonable. See, e.g., Blackman v. District of Columbia, 59 F.
Supp. 2d 37, 43 (D.D.C. 1999); Jefferson v. Milvets System Technology, Inc., 986 F. Supp. 6, 11 (D.D.C. 1997);
Ralph Hoar & Associates v. Nat'l Highway Transportation Safety Admin., 985 F. Supp. 1, 9-10 n.3 (D.D.C.
1997); Martini v. Fed. Nat'l Mtg Ass'n, 977 F. Supp. 482, 485 n.2 (D.D.C. 1997); Park v. Howard University,
881 F. Supp. 653, 654 (D.D.C. 1995).