## Facts

- Parents of a child with disabilities sought relief under the Individuals with Disabilities Education Act (IDEA), including private school tuition reimbursement from a public school district.
- The parents prevailed in IDEA litigation on the underlying tuition dispute.
- After prevailing, the parents sought reimbursement for fees paid to an educational consultant who assisted them during the IDEA proceedings.
- The parents relied on IDEA’s fee-shifting provision authorizing courts to “award reasonable attorneys’ fees as part of the costs” to prevailing parents.
- The district court limited the compensable period and treated the consultant’s relevant work as expert consulting, awarding a reduced amount.
- The court of appeals affirmed, concluding IDEA permitted reimbursement of expert fees.
- The Supreme Court granted review to decide whether IDEA’s fee-shifting provision authorizes recovery of expert fees.

## Issues

1. Whether IDEA’s authorization to award “reasonable attorneys’ fees as part of the costs” to prevailing parents permits reimbursement of expert or educational consultant fees.
2. Whether, given IDEA’s Spending Clause basis, a State receives clear statutory notice that accepting IDEA funds obligates it to pay prevailing parents’ expert fees.

## Decision

- The Supreme Court reversed and remanded.
- The Court held that IDEA does not authorize prevailing parents to recover expert fees under 20 U.S.C. § 1415(i)(3)(B).
- The Court reasoned that “costs” is a term of art that generally does not include expert fees, and the statute contains no explicit authorization to shift expert-fee liability to States.
- The Court rejected reliance on legislative history to supply notice of a funding condition not stated in the statutory text.

## Legal Principles

- Under the Spending Clause, conditions on a State’s receipt of federal funds must be stated unambiguously in the statute so the State can accept them knowingly.
- A fee- or cost-shifting statute will not be read to allow recovery of expert fees without explicit statutory authorization.
- The phrase “attorneys’ fees as part of the costs” permits awarding attorneys’ fees and does not expand “costs” to include expert fees absent clear text.
- Legislative history cannot impose Spending Clause funding conditions not clearly expressed in statutory language.

## Conclusion

IDEA’s fee-shifting provision permits prevailing parents to recover reasonable attorneys’ fees as part of taxable costs, but it does not authorize reimbursement of expert or consultant fees because the statute lacks explicit, unambiguous notice imposing that liability on States.


Arlington Cent. Sch. Dist. Bd. of Educ. v. Murphy, 548 U.S. 291 (2006)