21-1582 et al.

H.C. v. NYC DOE, et al.

In the

United States Court of Appeals

FOR THE SECOND CIRCUIT

AUGUST TERM 2022

No. 21-1582

H.C., INDIVIDUALLY, AND ON BEHALF OF 

J.C., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 21-1961

M.D., INDIVIDUALLY, AND ON BEHALF OF

L.D., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 21-2130

J.R., INDIVIDUALLY, AND ON BEHALF OF 

J.B., A CHILD WITH A DISABILITY,
2

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 21-2744

M.H., INDIVIDUALLY, AND ON BEHALF OF 

M.T., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 21-2848

A.G., INDIVIDUALLY, AND ON BEHALF OF 

R.P., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-259

D.P., INDIVIDUALLY, AND ON BEHALF OF 

S.P., A CHILD WITH A DISABILITY,
3

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-290

S.H., INDIVIDUALLY, AND ON BEHALF OF 

K.H., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-315

V.W., INDIVIDUALLY, AND ON BEHALF OF 

A.H., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-422

L.L., INDIVIDUALLY, AND ON BEHALF OF 

S.L., A CHILD WITH A DISABILITY,
4

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-568

H.W., INDIVIDUALLY, AND ON BEHALF OF 

M.W., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-586

H.A., INDIVIDUALLY, AND ON BEHALF OF 

M.A., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-772

N.G.B, INDIVIDUALLY, AND ON BEHALF OF 

J.B., A CHILD WITH A DISABILITY,
5

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-775

BOARD OF EDUCATION OF THE 

YORKTOWN CENTRAL SCHOOL DISTRICT,

Plaintiff-Counter-Defendant-Appellee,

v.

S.S., INDIVIDUALLY, AND ON BEHALF OF M.S., A MINOR,

C.S., INDIVIDUALLY, AND ON BEHALF OF M.S., A MINOR,

Defendants-Counter-Claimants-Appellants.

No. 22-855

A.W., INDIVIDUALLY, AND ON BEHALF OF 

E.D., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

No. 22-977

R.P., INDIVIDUALLY, AND ON BEHALF OF 
6

E.H.P., A CHILD WITH A DISABILITY,

Plaintiff-Appellant,

v.

NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendant-Appellee.

On Appeal from the United States District Court 

for the Southern District of New York

ARGUED: MAY 1, 2023

DECIDED: JUNE 21, 2023

Before: JACOBS, MENASHI, and MERRIAM, Circuit Judges.

Each appellant in these tandem appeals is a parent of a disabled 

child. Arguing that his or her child was entitled to benefits under the 

Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. 

§ 1415(i), each parent brought an administrative action against his or 

her local education agency and prevailed. Subsequently, each parent 

brought a federal action for attorneys’ fees pursuant to 20 U.S.C. 

§ 1415(i)(3)(B). In each case, the district court awarded less in

attorneys’ fees than the parent requested, and the parents now appeal. 

We hold that a district court awarding attorneys’ fees under the 

lodestar approach may consider the complexity of the matter both 

when it considers the number of hours reasonably expended and

when it considers the reasonable hourly rate. We also hold that the 

IDEA’s fee-shifting provision does not authorize the district court to 

award an unreasonable fee when the district court concludes that the 
7

education agency has unreasonably protracted proceedings. Finally, 

we hold that while a district court does not abuse its discretion when 

it adjusts excessive travel costs or fees that an attorney billed to a 

client, a district court abuses its discretion when it denies travelrelated fees altogether. We therefore reverse the district court’s denial 

of travel-related fees in No. 21-1961 and remand for further 

proceedings. We otherwise affirm.

BENJAMIN M. KOPP (Andrew K. Cuddy, on the briefs),

Cuddy Law Firm, P.L.L.C., Auburn, NY, for PlaintiffsAppellants.

REBECCA VISGAITIS (Richard P. Dearing, Clause S. 

Platton, Julie Steiner, Jane L. Gordon, Jesse A. Townsend,

MacKenzie Fillow, Kate Fletcher, Devin Slack, Philip W. 

Young, on the briefs) for Hon. Sylvia O. Hinds-Radix, 

Corporation Counsel of the City of New York, New York, 

NY, for Defendant-Appellee.

BENJAMIN M. KOPP, Cuddy Law Firm, P.L.L.C., Auburn, 

NY, for Defendants-Counter-Claimants-Appellants.

Mark C. Rushfield, Shaw, Perelson, May & Lambert, 

LLP, Poughkeepsie, NY, for Plaintiff-Counter-DefendantAppellee.

PER CURIAM:

These tandem appeals concern an important issue in our 

education law: fee shifting under the Individuals with Disabilities 

Education Act (“IDEA”), 20 U.S.C. § 1415(i). The general question 

presented is whether the district court abused its discretion in 

awarding less in attorneys’ fees and costs than requested. For the 
8

reasons stated below, we reverse the district court’s denial of travelrelated fees in No. 21-1961, M.D. v. New York City Department of 

Education, and remand for further proceedings. See infra Part V. We 

otherwise affirm the district courts’ awards of attorneys’ fees and 

costs.

BACKGROUND

Each appellant in these cases is the parent of a disabled child. 

The appellees are the local education agencies (“LEAs”) that the IDEA 

requires to provide services for each child.

In each case, the parent brought an administrative action under 

the IDEA against the child’s LEA. The Cuddy Law Firm (“CLF”) was 

retained to represent the parent and child in those administrative 

actions. Ultimately, CLF’s services were effective: the parents and 

children prevailed in each of the proceedings. 1 CLF then sought 

compensation for its services. But when the parents and CLF 

requested that the LEAs pay CLF’s fees, the LEAs refused on the 

ground that the fees requested were unreasonable.

As a result, the parents brought these individual actions in 

federal court seeking attorneys’ fees pursuant to 20 U.S.C. 

§ 1415(i)(3)(B). CLF updated the amount requested to include not 

only fees and costs related to the administrative proceedings but also 

fees and costs related to the federal actions. In each case, the district 

court evaluated the evidence presented by the parties and concluded 

that CLF’s request was unreasonable. Accordingly, the district court 

1 In Board of Education of the Yorktown Central School District v. C.S., the 

parent prevailed on appeal to the state review officer. See Affirmation in 

Opposition to Application for Attorney Fees and Costs ¶ 23, 

No. 17-CV-06542 (S.D.N.Y. May 5, 2021), ECF. No. 50.
9

calculated a reasonable fee and ordered the LEA to pay that fee. The 

parents and CLF appealed.

DISCUSSION

“We review a district court’s award for attorney’s fees, 

expenses, and costs for abuse of discretion.” Lilly v. City of New York, 

934 F.3d 222, 227 (2d Cir. 2019). Our review is “highly deferential” in 

this area because of “the district court’s inherent institutional 

advantages” in determining attorneys’ fees. Toussaint v. JJ Weiser, Inc., 

648 F.3d 108, 111 (2d Cir. 2011) (quoting McDonald ex rel. Prendergast 

v. Pension Plan of the NYSA-ILA Pension Tr. Fund, 450 F.3d 91, 96 (2d 

Cir. 2006)). Fee disputes “essentially are factual matters,” and the 

district courts have a “superior understanding of the litigation.” 

Hensley v. Eckerhart, 461 U.S. 424, 437 (1983). Moreover, the “essential 

goal” of fee shifting “is to do rough justice, not to achieve auditing 

perfection.” Fox v. Vice, 563 U.S. 826, 838 (2011). For these reasons, the 

Supreme Court has said that it “can hardly think of a sphere of judicial 

decisionmaking in which appellate micromanagement has less to 

recommend it.” Id.

The IDEA provides that “the court, in its discretion, may award 

reasonable attorneys’ fees as part of the costs ... to a prevailing party 

who is the parent of a child with a disability.” 20 U.S.C. 

§ 1415(i)(3)(B)(i)(I). The statute specifies that the reasonable fees 

awarded “shall be based on rates prevailing in the community in 

which the action or proceeding arose for the kind and quality of 

services furnished.” Id. § 1415(i)(3)(C).

To calculate reasonable attorneys’ fees under the IDEA, courts 

apply the “lodestar” method. A.R. ex rel. R.V. v. N.Y.C. Dep’t of Educ., 

407 F.3d 65, 79 (2d Cir. 2005). Under the lodestar method, a “fee award 

is derived by multiplying the number of hours reasonably expended 
10

on the litigation [by] a reasonable hourly rate.” G.M. ex rel. R.F. v. New 

Britain Bd. of Educ., 173 F.3d 77, 84 (2d Cir. 1999) (internal quotation 

marks omitted). In “rare circumstances,” the “district court may 

adjust the lodestar when it does not adequately take into account a 

factor that may properly be considered in determining a reasonable 

fee.” Millea v. Metro-North R.R. Co., 658 F.3d 154, 167 (2d Cir. 2011) 

(internal quotation marks omitted).

In determining the first component of the lodestar—the

number of hours reasonably expended—the district court may 

exclude hours that are “excessive, redundant, or otherwise 

unnecessary.” Raja v. Burns, 43 F.4th 80, 87 (2d Cir. 2022) (quoting 

Hensley, 461 U.S. at 434). But the district court also “has discretion 

simply to deduct a reasonable percentage of the number of hours 

claimed as a practical means of trimming fat from a fee application.” 

Id. The other component of the lodestar—the reasonable hourly rate—

“is the rate a paying client would be willing to pay,” Arbor Hill 

Concerned Citizens Neighborhood Ass’n. v. County of Albany, 522 F.3d 

182, 190 (2d Cir. 2008), after “considering all pertinent factors, 

including the Johnson factors,” Lilly, 934 F.3d at 230 (referencing 

Johnson v. Ga. Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974)).2

2 The Johnson factors include: “[t]he time and labor required”; “[t]he 

novelty and difficulty of the questions”; “[t]he skill requisite to perform the 

legal service properly”; “[t]he preclusion of other employment by the 

attorney due to acceptance of the case”; “[t]he customary fee”; “[w]hether 

the fee is fixed or contingent”; “[t]ime limits imposed by the client or the 

circumstances”; “[t]he amount involved and the results obtained”; the 

experience, reputation, and skill of the attorneys; whether the case is 

undesirable and may not be “pleasantly received by the community” or the 

attorney’s contemporaries; “[t]he nature and length of the professional 

relationship with the client”; and “[a]wards in similar cases.” Johnson, 488 

F.2d at 717-19.
11

I

Here, we are persuaded that there was no abuse of discretion 

in the district courts’ calculation of reasonable attorneys’ fees in each 

case. For example, the district court in J.R. cited recent cases from the 

Southern District of New York to determine the “prevailing market 

rate for experienced, special-education attorneys in the New York 

area” as the statute requires. J.R. v. N.Y.C. Dep’t of Educ., 

No. 19-CV-11783, 2021 WL 3406370, at *3 (S.D.N.Y. Aug. 4, 2021). The 

district court noted that it considered all the Johnson factors, and it 

made specific findings as to several of those factors: the case posed 

issues that were not “especially novel or difficult,” the subject matter 

was not “undesirable,” and the administrative proceedings took—in 

total—“less than two hours.” Id. at *4. The district court lowered the 

hourly rates for attorneys and paralegals on those grounds. It also 

found that the number of hours billed were excessive given that the 

matter “lack[ed] ... complexity,” so the district court reduced the total 

number of hours by twenty percent. Id. at *5. With these reductions, 

the district court cut CLF’s total request for attorneys’ fees by a little 

more than fifty percent. The district court did not abuse its discretion 

in calculating the lodestar in this way.

CLF makes two principal counterarguments on appeal. First, 

CLF argues that the district courts erred as a matter of law by 

evaluating the complexity of the underlying disputes twice: when 

considering the number of hours reasonably expended as well as 

when considering the reasonable hourly rate. CLF claims that this 

“double deduct[ion],” N.G.B. Br. 56, violated our statement in Millea

that a district court may not “double-count[] ... factors.” 658 F.3d at 

167. In Millea, we said that a district court “may not adjust the lodestar 

based on factors already included in the lodestar calculation itself.” 

Id. In other words, the district court may not use a factor both to 
12

compute the lodestar and to adjust the lodestar once it has been 

computed. The district courts here did something different, 

consulting the same factor when evaluating both components of the 

lodestar—reasonable hours and reasonable rates. CLF provides no 

reason to think that was impermissible. In fact, the complexity of the 

underlying dispute affects those two components of the lodestar. One 

of the Johnson factors is “[t]he novelty and difficulty of the questions” 

presented in the matter, so the complexity of the matter factors into 

the reasonable hourly rate. 488 F.2d at 718; see also Lilly, 934 F.3d at 

228. If a matter is complex, an attorney will reasonably expend more 

hours on it, but a simple matter will be subject to additional 

reductions in hours expended. We therefore hold that a district court 

does not err when it considers the complexity of the dispute both 

when it evaluates the time reasonably expended as well as the 

reasonable hourly rate. We see no error in the district courts’ lodestar 

calculations in this respect.

Second, CLF argues that it was erroneous to reduce its 

requested award at all because the LEAs unreasonably protracted the 

proceedings. See, e.g., M.H. Br. 33. CLF’s argument proceeds as 

follows. Subparagraph F of the statute, 20 U.S.C. § 1415(i)(3)(F), 

provides that the district court “shall” reduce an award of attorneys’ 

fees when, as applicable here, “the amount of the attorneys’ fees ... 

unreasonably exceeds the hourly rate prevailing in the community” 

or “the time spent and legal services furnished were excessive 

considering the nature of the action or proceeding.” Id. 

§ 1415(i)(3)(F)(ii)-(iii). But Subparagraph G, 20 U.S.C. § 1415(i)(3)(G), 

provides that those mandatory reductions “shall not apply” if the 

district court “finds that the State or local educational agency 

unreasonably protracted the final resolution of the action or 

proceeding.” Id.
13

CLF’s argument cannot prevail here because none of the district 

courts found as a factual matter that the LEAs unreasonably 

protracted the proceedings. For example, the district court in H.C. 

acknowledged that the LEA “fail[ed] to offer substantive relief at the 

resolution session,” “fail[ed] to adopt a consistent position on 

whether [it] would defend the case,” and “delay[ed] implementation” 

of the hearing officer’s final decision—which means that the LEA

could have hastened the proceedings if it had been better organized. 

H.C. v. N.Y.C. Dep’t of Educ., No. 20-CV-844, 2021 WL 2471195, at *8 

(S.D.N.Y. June 17, 2021). But the LEAs’ apparent disorganization in 

these cases does not necessarily establish that the LEA persisted when 

“there was absolutely no need to continue litigating,” which would 

suggest unreasonable protraction. Gary G. v. El Paso Indep. Sch. Dist., 

632 F.3d 201, 211 (5th Cir. 2011) (internal quotation marks omitted).

For that reason, we are not left with “a definite and firm conviction 

that the district court made a mistake” when it found no unreasonable 

protraction here, so we identify no clear error. Gater Assets Ltd. v. AO 

Moldovagaz, 2 F.4th 42, 52 (2d Cir. 2021) (internal quotation marks 

omitted); see also McDaniel v. County of Schenectady, 595 F.3d 411, 416 

(2d Cir. 2010) (noting that a “clearly erroneous factual finding” is an 

abuse of discretion). 

Moreover, even if a district court had found that an LEA

unreasonably protracted the proceedings,3 Subparagraph G would 

3 In M.H.’s case, the district court did not determine whether the New York 

City Department of Education unreasonably protracted the proceedings. 

See M.H. v. N.Y.C. Dep’t of Educ., No. 20-CV-1923, 2021 WL 4804031, at *25

(S.D.N.Y. Oct. 13, 2021) (“It is less clear that the Department’s 

disorganization and unpreparedness protracted the final resolution in the 

sense of making the proceedings ‘prolonged,’ or longer than what would 

ordinarily be needed for the conclusion of the proceedings.”). But the 

district court concluded that, even if the Department had done so, that 
14

not prohibit that district court from reducing the fees requested. That 

is because the IDEA authorizes an award only of “reasonable

attorneys’ fees,” 20 U.S.C. § 1415(i)(3)(B)(i) (emphasis added), and the 

IDEA further provides that those fees must be “based on rates 

prevailing in the community,” id. at § 1415(i)(3)(C). If an LEA

unreasonably protracts the proceedings—thereby triggering 

Subparagraph G—the mandatory reductions found in Subparagraph 

F would not apply, but the district court still would need to ensure 

that the fees awarded are reasonable and based on prevailing rates in 

accordance with § 1415(i)(3)(B)(i) and § 1415(i)(3)(C). The district 

court would not be free to award an unreasonable fee that a party

requests. We agree with those circuits that have held that when a 

district court finds that the LEA unreasonably protracted proceedings

the statute still requires the district court to conduct a lodestar 

calculation. See Somberg ex rel. Somberg v. Utica Cmty. Schs., 908 F.3d 

162, 181 (6th Cir. 2018) (holding that Subparagraph G “does not 

mandate that the district court abandon its discretion to ensure that 

fees are reasonable”); accord Williams ex rel. Williams v. Fulton Cnty. 

Sch. Dist., 717 F. App’x 913, 917 (11th Cir. 2017). 

For these reasons, we conclude that the district court in each 

case did not abuse its discretion when it awarded attorneys’ fees. We 

affirm the judgments—except as noted below with respect to 

No. 21-1961, M.D. v. New York City Department of Education.

II

CLF argues on appeal that the district courts should have 

awarded prejudgment interest here. But “[i]n a suit to enforce a 

“would not entitle CLF to more than a reasonable attorney’s fee” because 

“the plain language of the statute” authorizes only reasonable attorneys’ 

fees. Id. 
15

federal right, the question of whether or not to award prejudgment 

interest is ordinarily left to the discretion of the district court.” 

Gierlinger v. Gleason, 160 F.3d 858, 873 (2d Cir. 1998). The district 

courts that declined to award prejudgment interest did not abuse 

their discretion because “delay[s] in payment” may be remedied by 

“application of current rather than historic hourly rates.” Missouri v. 

Jenkins ex rel. Agyei, 491 U.S. 274, 284 (1989); see M.H. v. N.Y.C. Dep’t of 

Educ., No. 20-CV-1923, 2021 WL 4804031, at *31 (S.D.N.Y. Oct. 13, 

2021) (“The Court thus concludes that in IDEA cases, as in other feeshifting contexts, the Court should take into account ‘delay’ by using 

current rates in calculating a ‘reasonable’ attorneys’ fee.”).

We note that district courts may award prejudgment interest 

under 20 U.S.C. § 1415(i)(3)(B)(i). In interpreting the Civil Rights 

Attorney’s Fees Awards Act of 1976, 42 U.S.C. § 1988, the Supreme 

Court explained that “an enhancement for delay in payment is, where 

appropriate, part of a ‘reasonable attorney’s fee’” and that “an 

appropriate adjustment for delay in payment—whether by the 

application of current rather than historic hourly rates or otherwise—

is within the contemplation of the statute.” Jenkins, 491 U.S. at 282, 284 

(emphasis added). The same considerations apply to fee awards 

under the IDEA.

For these reasons, we will not disturb the district courts’ 

decisions with respect to prejudgment interest.

III

C.S. and S.S. contend that the district court erred when it failed 

to specify an entitlement to post-judgment interest in its judgment 

awarding attorney fees. “Pursuant to 28 U.S.C. § 1961, ‘the award of 

post-judgment interest is mandatory on awards in civil cases as of the 

date judgment is entered.’” Tru-Art Sign Co. v. Loc. 137 Sheet Metal 
16

Workers Int’l Ass’n, 852 F.3d 217, 223 (2d Cir. 2017) (alteration omitted)

(quoting Lewis v. Whelan, 99 F.3d 542, 545 (2d Cir. 1996)). For that 

reason, we understand the district court’s order to include postjudgment interest on the awarded fees and costs. We affirm the 

judgment based on that understanding.

IV

Separately, M.H. contends that the New York City Department 

of Education (“DOE”) violated the impartial hearing officer’s order 

and that she was entitled to equitable relief. See M.H. Br. 20. We affirm 

the district court’s dismissal of M.H.’s claims for equitable relief 

because the DOE has complied with the order: (1) the DOE has paid 

the invoices for all applied behavior analysis provided to M.H.; (2) as 

required, the DOE developed a new individualized education 

program (“IEP”) that placed the student in a non-public school that 

provides applied behavior analysis services; (3) there was no 

requirement that the IEP reference home-based applied behavior 

analysis and it is undisputed that there are no outstanding invoices 

for such services; (4) at the time of the complaint, M.H. had not chosen

a provider for the occupational therapy services and the order 

requires the DOE to fund such services at the parent’s chosen 

provider; and (5) the DOE confirmed that parent counseling and 

training services hours were outstanding and that it would pay for 

such services once M.H. had chosen a provider.
17

V

Last, CLF claims that the district court erred in denying it fees 

for time spent traveling to the administrative hearing for M.D.4 We 

agree.

The district court abused its discretion when it denied any 

travel-related fees to M.D.’s counsel. The district court reasoned that 

no fee award for time attributable to travel was warranted because it 

was “doubtful that a reasonable client would retain an Auburn or 

Ithaca attorney over a New York City attorney if it meant paying New 

York City rates and an additional five hours in billable time for each 

trip.” M.D. v. N.Y.C. Dep’t of Educ., No. 20-CV-06060, 2021 WL 

3030053, at *5 (S.D.N.Y. July 16, 2021) (quoting K.F. v. N.Y.C. Dep’t of 

Educ., No. 10-CV-5465, 2011 WL 3586142, at *6 (S.D.N.Y. Aug. 10, 

2011)). A district court may permissibly adjust excessive travel costs—

as many did in these cases. But the district court could not 

“eliminate[] all of the hours submitted by [CLF] as travel time” by 

denying travel-related fees altogether. Cruz v. Loc. Union No. 3 of Int'l 

Bhd. of Elec. Workers, 34 F.3d 1148, 1161 (2d Cir. 1994). We reverse the 

denial of travel-related fees, and we remand with instructions to 

award attorneys’ fees for two hours of travel time at the hourly rate 

the district court otherwise applied of $375, for a total of $750 in 

4 CLF also requested $245 in transportation costs for mileage and parking 

related to counsel’s attendance at the administrative hearing. The district 

court regarded that request as unreasonable because “[l]ocal counsel 

attending a hearing in New York City would likely take public transit, some 

sort of commuter rail, or a short car ride.” M.D. v. N.Y.C. Dep’t of Educ., 

No. 20-CV-06060, 2021 WL 3030053, at *7 (S.D.N.Y. July 16, 2021). The 

district court concluded that a “reasonable reimbursement” for such travel 

costs is “$50 each way, for a total of $100.” Id. CLF does not challenge that 

award on appeal. 
18

travel-related fees. M.D., 2021 WL 3030053, at *6; see also J.R., 2021 WL 

3406370, at *6 (awarding two hours of travel time); D.P. v. N.Y.C. Dep’t 

of Educ., No. 21-CV-27, 2022 WL 103536, at *13 (S.D.N.Y. Jan. 10, 2022) 

(same). We otherwise affirm.

* * *

We have considered the appellants’ remaining arguments, 

which we conclude are without merit. For the foregoing reasons, we 

reverse the district court’s denial of travel-related fees in No. 21-1961 

and remand for further proceedings. We otherwise affirm the 

judgments of the district courts.