For those of you following our hourly rate analysis in the fee substantiation area, we have posted in the past on the use of the Laffey Matrix and related permutations in our December 31, 2010 post. We now have an update for you from the Third Circuit Court of Appeals (federal level).
In Interfaith Community Organization v. Honeywell International Inc., 2013 WL 3379319 (3d Cir. July 8, 2013), the Third Circuit affirmed a district judge’s decision to use the adjusted/updated Laffey Matrix pegged to the CPI rather than the unadulterated Laffey Matrix. In doing so, the federal appeals court bolstered its affirmance based on the district court reasoning in Salazar v. District of Columbia, 123 F. Supp.2d 8, 15 (D.D.C. 2011).
However, a caution is in order here by us bloggers. The use of these matrices is factually intensive, so that they only have value depending on the forum, venue, and circumstances involved—really, a critical analysis or “check” on other information, except maybe in the D.C. area (at best).