Judge Sand said, “Because there is no requirement that a builder hire LEED-accredited professionals to attain LEED certification".
However in LEED 2012 it would appear that to complete a LEED program on a building in any of the rating systems 'you' would need to hold the LEED AP in that rating system:
[At least one (1) principal participant of the project team shall be a LEED Accredited Professional (AP) with a specialty most appropriate for the project.
In addition, two (2) individuals representing primary disciplines on the project are required to be LEED APs (any specialty) or Green Associates.] taken from LEED 2012 draft.
Might this prove to be the loophole that the plaintiff would need?