J.C. v. Regional School Dist. 10, Bd. of Educ.

US Court of Appeals

2002 U.S. App. LEXIS 950, 2002 WL 89061 (2nd Cir. 2002)

Jan 24, 2002

In 1995, J.C.’s parents requested that the Connecticut Regional School District 10 evaluate him for possible learning disabilities but they failed to do so. Consequently, in the fall of 1997, J.C.’s parents reiterated their request. This time the school agreed to hold a PPT meeting and J.C. was found to exhibit signs of ADHD. As a result of these findings, J.C. underwent a psychological assessment but the PPT ultimately decided that special education services or accommodations were not warranted. A year later, J.C.’s parents were notified that he had vandalized a school bus and was suspended from school. As a result, the family’s lawyer send a letter to the Region 10 Board of Education (“Board”) requesting a PPT, a due process hearing and an independent evaluation of J.C. in order to determine his special education needs. The Board granted these requests and concluded that J.C. suffered from an educational disability and his behavior at school was a direct result of this disability. J.C. was subsequently allowed back in school. At the Due Process hearing – the hearing officer refused to adopt the results as an official order out of fear that doing so would subject the Board to liability for attorney’s fees. Nonetheless, J.C. and his parents sued the Board for attorney’s fees claiming that J.C. was a prevailing party because the PPT had given him the relief he was soliciting at the due process hearing.

Pursuant to the Individuals with Disabilities in Education Act (IDEA), the District Court used the catalyst theory of recovery (finding a causal relationship based on the pressure that the lawsuit caused in bringing about the result desired) to award attorney’s fees. However, the catalyst theory of recovery was rejected in Buckhannon Board and Care Home, Inc. v. West Virginia Department of Health and Human Resources, 532 U.S. 598 (2001), and thus the Court of Appeals reversed the District’s Court’s decision. Centering its opinion on the definition of “prevailing party” constructed in Buchannon, the court states, “to be a prevailing party, one must either secure a judgment on the merits or be a party to a settlement agreement that is expressly enforced by the court through a consent decree.” The plaintiff argued that because the IDEA differs from other statutes with fee-shifting provisions, it requires a different understanding of prevailing party. In the alternative, even if Buckhannon governs the IDEA, the award of attorney’s fees is appropriate because the decision to create an individualized education program (“IEP”) was more of a judicial consent decree than a private settlement. However, the Court rejected these arguments as well as the plaintiff’s claim that even if he could not prevail under the IDEA, he should succeed under the broader Rehabilitation Act. The Court of Appeals concluded that the Supreme Court’s holding in Buckhannon governs the claims asserted by J.C. in this appeal and thus they had no choice but to reverse the decision of the District Court.

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