## Facts

- Parents of children with disabilities challenged the New York City Department of Education’s (DOE) proposed special-education services in four separate state administrative proceedings under the Individuals with Disabilities Education Act (IDEA).
- In two matters, impartial hearing officers (IHOs) ruled for the parents on the merits.
- In two matters, the disputes were resolved through settlement terms embodied in IHO “Statements of Agreement and Order,” and one case included a later order resolving an additional claim.
- The parents then filed federal actions seeking attorneys’ fees for work performed in the administrative proceedings under 20 U.S.C. § 1415(i)(3)(B).
- The district court awarded fees, finding the parents were “prevailing parties” and applying Southern District of New York (SDNY) market rates to determine reasonable hourly rates.
- DOE appealed, arguing (1) the parents were not prevailing parties under Buckhannon because the results were not sufficiently “judicially sanctioned,” and (2) SDNY rates were the wrong “relevant community.”

## Issues

1. Whether parents who obtain relief in IDEA state administrative proceedings—through IHO merits decisions or settlements incorporated into IHO orders—qualify as “prevailing parties” eligible for attorneys’ fees under § 1415(i)(3)(B) after Buckhannon.
2. Whether the district court abused its discretion by using SDNY market rates as the “relevant community” for calculating reasonable attorneys’ fees.

## Decision

- The Second Circuit affirmed the fee awards.
- The court held the parents were prevailing parties because they achieved a material alteration of the parties’ legal relationship that was sufficiently sanctioned through administrative adjudication.
- IHO decisions on the merits carried the required imprimatur because they were binding determinations issued by neutral adjudicators with authority under the IDEA framework.
- Settlement outcomes recorded in formal IHO orders also satisfied Buckhannon because the IHO orders did more than reflect private agreements; they officially embodied the relief and resolved the disputes.
- The court held the district court did not abuse its discretion in using SDNY rates as the relevant market for reasonable hourly rates in the fee litigation.

## Legal Principles

- A party is “prevailing” for fee-shifting purposes only if it obtains a material alteration of the parties’ legal relationship that is officially sanctioned (Buckhannon standard).
- For IDEA fee requests, relief obtained through state administrative adjudication can satisfy the “official sanction” requirement where orders are issued by authorized, neutral decision-makers and have binding legal effect.
- Settlements may support prevailing-party status when the settlement terms are incorporated into a formal administrative order that resolves the dispute, as opposed to a purely private agreement without official approval.
- IDEA attorneys’ fee awards are reviewed for abuse of discretion; district courts have broad discretion so long as they apply correct legal standards and base rates and hours on record support.
- The relevant community for hourly rates generally may be the forum district where the fee action is litigated; a departure requires persuasive justification.

## Conclusion

The Second Circuit held that parents who secure enforceable relief in IDEA administrative proceedings—either through IHO merits rulings or settlement terms embodied in IHO orders—are prevailing parties eligible for attorneys’ fees, and it upheld the district court’s use of SDNY forum rates as a reasonable measure of prevailing market rates.


A.R. ex rel. R.V. v. N.Y.C. Dep't of Educ., 407 F.3d 65 (2d Cir. 2005)