H.E., Individually and on behalf of H.F.; C.E., Individually and on behalf of D.E.; M.T., Individually and on behalf of T.T., Appellants
WALTER D. PALMER LEADERSHIP LEARNING PARTNERS CHARTER SCHOOL; COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF EDUCATION
Submitted under Third Circuit L.A.R. 34.1(a) on September 19,
Appeal from the United States District Court for the Eastern
District of Pennsylvania (E.D. Pa. Civil Action No.
2:15-cv-03864) Honorable Wendy Beetlestone, U.S. District
J. Berney Morgen N. Black-Smith Law Offices of David J.
Berney Counsel for Appellants
G. Knorr, III Josh Shapiro Claudia M. Tesoro Office of
Attorney General of Pennsylvania Counsel for Appellee
Commonwealth of Pennsylvania Department of Education
Before: AMBRO, KRAUSE, and SCIRICA, Circuit Judges
KRAUSE, Circuit Judge.
Individuals with Disabilities Education Act contains a
fee-shifting provision, which, provided that a parent of a
child with a disability has emerged as "a prevailing
party" in administrative or judicial proceedings
challenging violations of the Act, renders the parent
eligible for an award of attorneys' fees. 20 U.S.C.
§ 1415(i)(3)(B). The parents in this case obtained a
court order vindicating their right to an administrative due
process hearing under the Act, see id. §
1415(f), but the District Court denied their request for
attorneys' fees, reasoning that they had received only
interlocutory procedural relief and, for that reason, were
not prevailing parties. Because that conclusion is contrary
to this Court's decisions in M.R. v. Ridley School
District, 868 F.3d 218 (3d Cir. 2017), and Bagby v.
Beal, 606 F.2d 411 (3d Cir. 1979), where we explained
that success on a claim for procedural relief can constitute
"a victory 'on the merits' that confer[s]
'prevailing party' status, " M.R., 868
F.3d at 226 (quoting Bagby, 606 F.2d at 415), we
will reverse the District Court's denial of
attorneys' fees and remand for proceedings consistent
with this opinion.
in this case are the parents of three children with
disabilities, each of whom attended Walter D. Palmer
Leadership Learning Partners Charter School before it
permanently closed in December 2014. This case relates to
Plaintiffs' efforts to obtain compensatory education for
their children under the Individuals with Disabilities
Education Act ("IDEA"), 20 U.S.C. §§
1400-1482. Before recounting the history of those efforts, we
briefly review the statutory framework from which
Plaintiffs' claims arose.
IDEA provides to children with disabilities "an
enforceable substantive right to [a free appropriate] public
education in participating States, " while conditioning
federal financial assistance to those states on their
"compliance with the substantive and procedural goals of
the Act." Honig v. Doe, 484 U.S. 305, 310
(1988); see 20 U.S.C. § 1412(a)(1). Because
Congress was aware that schools had "all too often"
denied a free appropriate public education to children with
disabilities "without in any way consulting" the
children's parents, the Act also "establishes
various procedural safeguards that guarantee parents both an
opportunity for meaningful input into all decisions affecting
their child's education and the right to seek review of
any decisions they think inappropriate." Honig,
484 U.S. at 311. Those procedural safeguards allow parents to
file an administrative complaint challenging "any matter
relating to the identification, evaluation, or educational
placement of the child, or the provision of a free
appropriate public education to such child, " 20 U.S.C.
§ 1415(b)(6)(A); they provide for "an impartial due
process hearing" in response to such a complaint,
id. § 1415(f)-(h); and they allow federal
district courts to "award reasonable attorneys' fees
as part of the costs" to parents who are
"prevailing part[ies]" in the due process
proceedings, id. § 1415(i)(3)(B). Should school
districts and parents wish to sidestep this due process
procedure for any reason, they may submit to the Act's
statutory mediation procedures, see id.
§1415(e), which, if successful, culminate in legally
binding settlement agreements, see id. §
IDEA's "elaborate and highly specific procedural
safeguards" provide parents with a means of enforcing
the Act's "general and somewhat imprecise
substantive admonitions." Bd. of Educ. v.
Rowley, 458 U.S. 176, 205 (1982). For that reason,
Congress "placed every bit as much emphasis" on
school districts' compliance with those procedural
safeguards as it did on their compliance with the Act's
substantive standards. Id. at 205-06. As the Supreme
Court has observed, "the importance Congress attached to
[the IDEA's] procedural safeguards cannot be gainsaid,
" for "the congressional emphasis" on those
safeguards "demonstrates the legislative conviction that
adequate compliance with the procedures prescribed would in
most cases assure much if not all of what Congress wished in
the way of substantive content." Id. at 206.
importance of an order enforcing those procedural safeguards
is the subject of this appeal, the facts of which we recount
Factual and ...