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M.R. v. Ridley Sch. Dist.

M.R. v. Ridley Sch. Dist.

United States Court of Appeals for the Third Circuit

March 30, 2017, Argued; August 22, 2017, Opinion Filed

No. 16-2465

Opinion

 [*220]  OPINION OF THE COURT

KRAUSE, Circuit Judge.

] Under the Individuals with Disabilities Education Act, a parent of a child with a disability can bring administrative and judicial proceedings to challenge a school district's alleged violations of the Act, and, if the parent emerges as "a prevailing  [*221]  party," the parent is then eligible for an award of attorneys' fees. 20 U.S.C. § 1415(i)(3)(B). This case presents the question whether a fee award is available to parents who, after unsuccessfully challenging a school district's proposed educational placement for their child, later obtain a court order requiring the school district to reimburse them for the costs of the child's "stay put" placement—the "then-current educational placement" in which the Act permitted the child [**2]  to remain while administrative and judicial proceedings were pending. Id. § 1415(j). We answer this question in the affirmative and conclude, consistent with the Act's text and with the opinions of this Court and the other Courts of Appeals, that ] a court-ordered award of retrospective and compensatory relief, even if awarded under the Act's "stay put" provision, 20 U.S.C. § 1415(j), confers "prevailing party" status. We therefore will reverse the District Court's denial of attorneys' fees and remand for proceedings consistent with this opinion.

I. Background

This case pertains to a long-running dispute between Appellants, the parents of E.R., and Appellee, the Ridley School District, concerning E.R.'s schooling and Ridley's obligations under the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. §§ 1400-1482. Before turning to the details of that dispute, we briefly review the statutory framework from which it arose.

A. Statutory Context

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868 F.3d 218 *; 2017 U.S. App. LEXIS 15944 **; 2017 WL 3597707

M.R.; J.R., Parents of Minor Child E.R., Appellants v. RIDLEY SCHOOL DISTRICT

Prior History:  [**1] On Appeal from the United States District Court for the Eastern District of Pennsylvania. (E.D. Pa. Civil Action No. 2:11-cv-02235). Honorable Mitchell S. Goldberg, U.S. District Judge.

M.R. v. Ridley Sch. Dist., 744 F.3d 112, 2014 U.S. App. LEXIS 3083 (3d Cir. Pa., Feb. 20, 2014)

CORE TERMS

prevailing party, stay put, reimbursement, school district, placement, attorney's fees, district court, disabilities, confer, temporary, injunction, compensatory relief, forward-looking, merits, contempt order, prevailing, obligations, backward-looking, proceedings, eligible, cases, preliminary injunction, private school, fee award, costs, private-school, merits-based, free appropriate public education, injunctive relief, statutory context

Civil Procedure, Attorney Fees & Expenses, Basis of Recovery, Statutory Awards, Education Law, Discrimination in Schools, Disability Discrimination, Individuals With Disabilities Education Act, Appeals, Standards of Review, Abuse of Discretion, Remedies, Costs & Attorney Fees, Attorney Fees & Expenses, De Novo Review, Questions of Fact & Law, Governments, Legislation, Interpretation, Statutory Remedies & Rights