Irvine Unified School District v. K.G., No. 14-56457 (9th Cir. 2017)
Annotate this CaseThis case arose from a dispute over which California government entity would be responsible for funding the education of K.G. pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400(d)(1)(A). The School District contended that the district court erred in granting K.G. relief from its original judgment denying attorneys' fees. The court concluded that the district court applied the correct legal rule in evaluating whether to grant relief pursuant to Rule 60(b)(1) where the district court's determination that K.G.'s delay in pursuing Rule 60(b) relief was understandable in light of the original attorney's poor mental and physical health; K.G. was the prevailing party entitled to attorney fees because K.G.'s prayer was answered in full when the ALJ designated the School District as the responsible agency and granted K.G.'s requested relief; K.G. qualified as a prevailing party under the IDEA, and this victory was not trivial or merely technical; but it was not clear from the district court's award that it took into account forgoing considerations in reducing the fees originally requested. Accordingly, the court affirmed in part, vacated in part, and remanded.
Court Description: Individuals with Disabilities Education Act /. Attorneys’ Fees The panel affirmed the district court’s grant of relief from judgment but vacated its award of attorneys’ fees to a student in an action under the Individuals with Disabilities Education Act. On remand from a ruling that student K.G.’s school district was the agency responsible for K.G.’s free appropriate public education, K.G. moved for statutory attorneys’ fees. The district court denied the motion on the ground that K.G. was not a prevailing party but subsequently granted relief from judgment under Federal Rule of Civil Procedure 60(b) and awarded fees. The panel held that the district court did not abuse its discretion in granting relief under Rule 60(b)(1) on the ground of excusable neglect. The panel held that K.G. was a prevailing party entitled to attorneys’ fees because K.G. achieved the benefit sought, a decision as to which agency was responsible to provide a free appropriate public education. The panel rejected the argument that K.G. could not have benefitted from the litigation because K.G. graduated with a high school diploma months before the district court decided the case. The panel held that K.G.’s victory was not trivial or merely technical. IRVINE USD V. K.G. 3 The panel held, however, that it was not clear whether the amount of attorneys’ fees awarded was reasonable because much of counsel’s work took place after K.G.’s graduation. The panel vacated the fee award and remanded for the district court to determine whether the hours billed following K.G.’s graduation were truly the result of advocacy reasonably calculated to advance K.G.’s interests. Concurring and dissenting in part, Judge Callahan joined all of the majority opinion except for Section III C, addressing the amount of fees. Judge Callahan wrote that there was no justification in either the IDEA or case law for limiting an award of attorneys’ fees to a prevailing party based on whether the student graduated.
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