Tina M. v. St. Tammany Parish Sch. Bd.

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Plaintiffs filed suit on behalf of their minor son seeking attorneys' fees under the Individuals with Disabilities Education Act's (IDEA), 20 U.S.C. 1415(i)(3)(B), fee-shifting provision. The district court held that plaintiffs were the prevailing party by virtue of having obtained a “stay-put” order under the IDEA and awarded plaintiffs attorneys’ fees. The court held that plaintiffs are not the prevailing party by virtue of having invoked the IDEA's stay-put provision and the court concluded that its holding is consistent with several other circuit courts that have addressed the issue. Contrary to the district court’s conclusion, the ALJ’s stay-put order was not a ruling on the merits; nor is the stay-put order a “similar form of judicially sanctioned relief” sufficient to confer prevailing party status; the court disagreed with the district court’s reasoning that the stay-put order was essentially a preliminary injunction and that pursuant to the court's case law in this context, plaintiffs were entitled to attorneys’ fees; and, in Davis v. Abbott, the court recently reiterated the importance of a party having achieved relief on the merits for the purposes of determining prevailing party status in the context of interlocutory injunctive relief. Accordingly, the court reversed and rendered judgment for defendants. View "Tina M. v. St. Tammany Parish Sch. Bd." on Justia Law