Sunday, October 27, 2013

Doe v. Boston Public Schools case brief

Doe v. Boston Public Schools case brief summary
358 F.3d 20 (2004)

Appellant individual sued appellee public schools under the Individuals with Disabilities Education Act and sought placement in a private therapeutic day school. After negotiations, the public schools offered her the placement. The United States District Court for the District of Massachusetts dismissed the individual's request for attorneys' fees because she was not a "prevailing party." The individual appealed.

  • Jane Doe sued the City of Boston Public Schools (defendant) under the Individuals with Disabilities Education Act (IDEA), seeking placement in a private therapeutic day school. 
  • The parties engaged in negotiations, after which Boston offered Doe the placement she sought. 
  • Doe requested that the placement be read into the record and be signed by the Bureau of Special Education Appeals hearing officer. 
  • The hearing officer refused to sign. 
  • Doe requested to be awarded attorney’s fees. 
  • The court dismissed her complaint on the ground that she was not a “prevailing party.”

  • The central question that the appellate court had to decide was under the United States Supreme Court's definition of "prevailing party," in which the Court held that under certain federal fee-shifting statutes, attorneys' fees could be awarded only to parties who received a final judgment on the merits or obtained a court-ordered consent decree, applied to the definition of "prevailing party" under the Individuals with Disabilities Education Act (IDEA) thus precluding recovery of attorneys' fees following a private settlement. 
  • The appellate court found that the Court's holding was presumed to apply generally to all fee-shifting statutes that used the "prevailing party" terminology, including the IDEA. 
  • The presumption against settlement-based fee awards was not rebutted by the statutory text, structure, or legislative history of the statute. 
  • Therefore, plaintiffs under the IDEA who achieved their desired result via private settlement could not, in the absence of judicial imprimatur, be considered prevailing parties.
  • Thus, the individual could not recover attorneys' fees under the statute.


The judgment of the district court was affirmed.

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

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