This case involved a motion for attorney's fees following a plaintiff's successful bench trial judgment of $150,000 against Howard University in a civil rights matter. The court awarded fees at a rate of $300 per hour based on the prevailing market rate for experienced civil rights attorneys. The reasoning relied on Supreme Court precedents in Hensley v. Eckerhart and Blum v. Stenson, as well as the D.C. Circuit's en banc decision in Save Our Cumberland Mountains, Inc. v. Hodel, which require applying the market rate even for attorneys who charge reduced rates, and the retainer agreement's proviso that any court-awarded fees would control the amount owed. The university did not contest the hours worked or costs requested.
In Park v. Howard University, plaintiff Soon Y. Park alleged that Howard University discriminated against her on the basis of national origin and gender in violation of Title VII of the Civil Rights Act of 1964, including by delaying her promotion and creating a hostile work environment through ongoing conduct. Earlier, the court found for the plaintiff and awarded lost wages and medical expenses while noting a basis for further damages; this memorandum addresses the amount of compensatory damages under the 1991 amendments to Title VII. The court decided to award $150,000 in compensatory damages, holding that the 1991 Act's provisions for such damages apply to the defendant's pre-amendment conduct because the discriminatory actions constituted a continuing violation that persisted after the amendments took effect. The core reasoning relied on Supreme Court precedents establishing a firm rule of retroactivity for new rules of federal law, such as Bradley v. Richmond School Board and Harper v. Virginia Department of Taxation, while distinguishing the case from Landgraf v. USI Film Products due to the absence of prompt remedial action by the defendant and the ongoing nature of the misconduct; the award was also limited by the two-year back-pay accrual period under Title VII.
This case involved claims by several senior GAO employees over age 50 that they were denied promotion to the Senior Executive Service through the Executive Candidate Development Program and other means due to age discrimination. After a trial, the court found that the GAO had legitimate, nondiscriminatory reasons for not selecting the plaintiffs, based on their employment records and supervisor testimony indicating they were not among the most exceptional candidates required for such positions. Statistical analyses presented at trial further demonstrated that the selection process was age-neutral. The court therefore ruled in favor of the defendant, concluding that age played no role in the decisions.
The case involved Jacqueline Randall's claims of medical malpractice and lack of informed consent regarding prenatal care at Walter Reed Army Hospital under the Federal Tort Claims Act, specifically the handling of her abnormal pap smear results indicating CIN-1, follow-up colposcopic exams showing possible HPV-related changes, and decisions not to perform a biopsy or fully communicate results while she was pregnant with her daughter Kimberly. After a bench trial, the court issued findings of fact detailing the exams, medical records, expert testimony on standard practices for pregnant patients, and the separation of OB and GYN clinics at the hospital. The core reasoning focused on whether the physicians' recommendations for postpartum follow-up, absence of biopsy due to pregnancy risks, and overall treatment aligned with accepted medical standards without evidence of negligence.
In this case, the defendant moved under 28 U.S.C. § 2255 to vacate her sentence after pleading guilty to drug and firearm charges, alleging due process violations from a 16-day pre-indictment detention, denial of counsel during arrest, ineffective assistance of counsel, failure to credit substantial assistance, and (in a proposed amendment) innocence due to duress that also rendered her plea involuntary. The court denied the motion, the request to amend, and an extension of time to respond. It held that under Tollett v. Henderson, a valid guilty plea waives collateral attacks on pre-plea constitutional claims, limiting review to whether counsel's advice rendered the plea involuntary or unintelligent. Applying Hill v. Lockhart and Strickland v. Washington, the court found the defendant failed to show counsel's performance was objectively unreasonable or that any errors would have led her to insist on trial rather than pleading guilty.
The case concerned enforcement of a permanent injunction under the Stewart B. McKinney Homeless Assistance Act, which requires federal landholding agencies to identify and make excess, surplus, unutilized, or underutilized properties available for use by homeless assistance providers. Plaintiffs moved to modify the injunction to conform to 1990 statutory amendments regarding quarterly canvassing of properties, reporting deadlines, suitability determinations by HUD, and related procedures. The court adopted a compromise requiring comprehensive canvassing in the first and third quarters and supplemental canvassing in the others, shortened HUD's suitability review period to thirty days, and rejected or modified other proposed changes based on the plain language of the statute and prior interpretations of the injunction while accounting for agency operational concerns.