Arlington Central School Dist. Bd. of Ed. v. Murphy, 548 U.S. 291 (2006)
Primary Holding
The Individuals with Disabilities Education Act (IDEA) does not authorize prevailing parents to recover attorneys' fees for expert services rendered in actions brought under the Act.
In the case of Arlington Central School Dist. Bd. of Ed. v. Murphy, the Supreme Court decided that parents who win cases under the Individuals with Disabilities Education Act (IDEA) cannot get reimbursed for the fees of expert consultants they hired. This ruling is important because it limits the financial support available to parents who are trying to secure appropriate education for their children with disabilities. For consumers, this means that while parents can still get their legal fees covered if they win, they can't count on getting back money spent on expert advice, which can be a significant cost. This case is relevant for parents navigating special education disputes, as it highlights the importance of understanding what expenses can and cannot be recovered in these situations.
AI-generated plain-language summary to help you understand this case
Two parents prevailed in a lawsuit against a school district, based on the claim that the Individuals with Disabilities Education Act (IDEA) required the district to pay for their child's tuition in private school. Once the judgment was upheld, they sued for reimbursement of the fees that they had paid for their experts during the trial. The argument was based on the IDEA provision stating that " reasonable attorneys' fees" could be included as part of the court costs.
Whether the fee-shifting provision of the Individuals with Disabilities Education Act authorizes prevailing parents to recover fees for services rendered by experts in IDEA actions.
The judgment is reversed.
The Court felt that the plain wording of the statute was unambiguous, and thus it refused to consider legislative history or other extrinsic evidence, as the parents argued that it should. Congress has repeatedly introduced laws that are specifically designed to overrule this decision, but they have not yet passed.
- Court
- Supreme Court
- Decision Date
- April 19, 2006
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Alito
- Damages Awarded
- N/A
- Data Quality
- high
Schaffer v. Weast, 546 U.S. 49 (2005)
Consumer LostThe burden of persuasion in an impartial due process hearing under the Individuals with Disabilities Education Act (IDEA) lies with the party seeking relief.
Board of Ed. of City School Dist. of New York v. Tom F., 552 U.S. 1 (2007)
Consumer LostThe Supreme Court affirmed the lower court's decision by an equally divided Court, indicating that the ruling of the Second Circuit stands without establishing a new legal principle or rule.
Winkelman v. Parma City School Dist., 550 U.S. 516 (2007)
Consumer WonParents of a child with disabilities have the right to represent themselves and their child in court proceedings under the Individuals with Disabilities Education Act (IDEA), even if they are not licensed attorneys.
Richlin Security Service Co. v. Chertoff, 553 U.S. 571 (2008)
Consumer WonThe Equal Access to Justice Act (EAJA) allows a prevailing party in a case against the government to recover attorney's fees, including paralegal services, at the prevailing market rate, rather than limiting recovery to the cost incurred by the attorney's firm.