Meridian Joint Sch. Dist. v. D.A., No. 13-35329 (9th Cir. 2015)
Annotate this CaseMSD appealed the district court's determination that Mathew, who has Asperger's Syndrome, was entitled to the preparation of an Independent Educational Evaluation (IEE) at public expense under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400; an award of attorneys' fees to Mathew's parents; and an injunction against Mathew's graduation from high school. The court found no error in the district court’s affirmance of the hearing officer’s determination that Matthew was entitled to an IEE at public expense; the parents’ request for attorneys’ fees is more analogous to an independent claim than an ancillary proceeding and thus was timely filed; by procuring an IEE at public expense, the parents were “prevailing parties;" because the plain language of the IDEA limits awards of attorneys’ fees pursuant to 20 U.S.C. 1415(i)(3)(B)(i)(I) to instances in which the child has been determined to need special education services, and Matthew had not been found to need such services, the parents are not eligible for an award of attorneys’ fees under the IDEA; and the "stay-put" injunction preventing Matthew’s graduation from high school must be lifted. Accordingly, the court affirmed in part, reversed in part, and vacated in part.
Court Description: Individuals with Disabilities Education Act. The panel affirmed in part and reversed in part the district court’s judgment and vacated an injunction in an action under the Individuals with Disabilities Education Act. The parties disagreed as to whether a student was entitled to special education services under the IDEA. Affirming in part, the panel held that the district court did not err in affirming a hearings officer’s determination that the student was entitled to an Independent Educational Evaluation at public expense. Reversing in part, the panel held that although the student’s parents’ request for attorneys’ fees was timely and they were prevailing parties, they were not eligible for an award of fees under 20 U.S.C. § 1415(i)(3)(B) because neither was a “parent of a child with a disability.” Agreeing with the Eleventh Circuit, and disagreeing with the Sixth and Seventh Circuits, the panel concluded that for purposes of MERIDIAN JOINT SCH. DIST. NO. 2. V. D.A. 3 choosing the most relevant state statute of limitations, a request for attorney’s fees is more analogous to an independent claim than an ancillary proceeding. Agreeing with the Fifth Circuit, the panel held that the parents were not parents of a child with a disability for purposes of an award of attorneys’ fees under § 1415(i)(3)(B) because their child had not been determined to need special education services. The panel vacated the district court’s “stay-put” injunction against the student’s graduation from high school.
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