Richardson v. Omaha School District, No. 19-2058 (8th Cir. 2020)
Annotate this Case
The Eighth Circuit affirmed the district court's grant of the school district's motion to dismiss in part and motion for summary judgment in an action brought under section 504 of the Rehabilitation Act, the Individuals with Disabilities Education Act (IDEA), and Title II of the Americans with Disabilities Act.
The court held that the district court did not err in dismissing plaintiffs' request for attorneys' fees as time barred by the 90-day statute of limitations in Arkansas Code section 6-41-216(g), Arkansas's statutory framework for IDEA compliance. The court explained that the claim for attorneys' fees is ancillary to judicial review of the administrative decision. The court also held that the district court did not err by granting summary judgment to the school district where there is no genuine issue of material fact about whether the school district acted in bad faith or with gross misjudgment with respect to plaintiffs' claim that their son was the victim of peer and teacher bullying.
Court Description: [Gruender, Author, with Arnold and Shepherd, Circuit Judges] Civil case - Individuals with Disabilities Education Act. In this action, the parents of a student alleged he was discriminated against under Section 504 of the Rehabilitation Act and the IDEA and sought attorneys' fees as the prevailing party in the state administrative proceedings; the district court did not err in dismissing the request for attorneys' fees as time barred by the 90-day statute of limitations for merits actions contained in Arkansas Code section 6-41-216(g), part of Arkansas's statutory framework for IDEA compliance; the claims for attorneys' fees is ancillary to judicial review of the administrative decision; with respect to plaintiff's IDEA and Rehabilitation Act claims, none of the evidence concerning bullying created a genuine dispute of material fact about whether the school district acted in bad faith or with gross misjudgment. [ April 24, 2020 ]
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.