Monday, October 28, 2013

Barrios v. California Interscholastic Federation case brief

Barrios v. California Interscholastic Federation case brief summary
277 F.3d 1128 (2002)

CASE SYNOPSIS
Plaintiff disabled coach sued defendants athletic associations alleging violations of the Americans with Disabilities Act of 1990, and state law claims. The parties entered into a settlement agreement and the coach moved for attorneys fees and costs as the prevailing party. The United States District Court for the Central District of California denied motion. The coach appealed.

CASE FACTS
The coach, who was a paraplegic, was the assistance baseball coach for a high school baseball team. He had coached high school baseball from an athletic wheelchair for four consecutive seasons in the athletic association's league. In 1999, the coach was prevented from coaching in the field by the athletic association. Despite numerous attempts to settle the matter and despite numerous assurances that the coach would be permitted on the field, the coach was consistently excluded from on-filed coaching. The coach filed a complaint and the parties eventually entered into a settlement agreement.

DISCUSSION
  • The court of appeals held that the coach was a prevailing party because he could enforce the terms of the settlement agreement against the athletic association. 
  • The district court's finding that the relief the coach sought for himself already had been granted prior to the filing of his complaint was clearly erroneous because on at least two separate occasions prior to the initiation of the litigation, the athletic association had assured the coach that a variance either was being sought or had been granted, but nonetheless, the coach was prohibited from coaching his team.

OUTCOME

The judgment, which denied an award of attorney fees, was reversed and the matter was remanded for further proceedings.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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