District Judge Disregarded AI Computation On Hourly Rates.
Okay, everyone following our blog, we have our first Artificial Intelligence (AI) case on a fee motion.
In J.G. v. New York City Dept. of Education, No. 23 Civ. 949 (PAE), S.D.N.Y. (Doc. 32, 2/22/2024), the district court was considering a fee request to a prevailing party after two administrative hearings under the Individuals with Disabilities Education Act (IDEA) fee-shifting statute. The requesting party asked for $113,484.62 in fees and costs, with the district court ultimately awarding $53,050.13 after the party eschewed a $54,300 settlement offer. In reaching its result (after acknowledging IDEA is a niche legal area not akin to more generalized practices), what the district court did do was to reject an artificial intelligence analysis of hourly rates as being unpersuasive and unreliable. In so doing, it quoted other cases determining that AI data needed to be really scrutinized by the attorneys relying on it before submission of that data to the court.
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