## Facts

- Jane Doe, a nineteen-year-old student with a severe mental disability, was entitled to special education services under the Individuals with Disabilities Education Act (IDEA).
- Boston Public Schools, the responsible local educational agency, proposed continuing Doe’s placement at McKinley Vocational High School.
- While Doe was hospitalized, her father requested placement in a private residential program; Boston rejected that request.
- Doe invoked IDEA due process procedures before the Massachusetts Bureau of Special Education Appeals (BSEA) and sought placement in a therapeutic day school; the BSEA scheduled a hearing.
- On the eve of the administrative hearing, Boston offered Doe placement in a private therapeutic day school, which Doe accepted; no BSEA merits decision, consent decree, or court order issued regarding the dispute.
- Doe filed a federal action seeking attorneys’ fees under IDEA’s fee-shifting provision, claiming she was a “prevailing party” because she obtained the requested placement through settlement.

## Issues

1. Whether an IDEA plaintiff who obtains the requested educational placement through a private settlement, without a judicial or administrative order, is a “prevailing party” eligible for attorneys’ fees under 20 U.S.C. § 1415(i)(3)(B).

## Decision

- The First Circuit affirmed dismissal of Doe’s fee complaint.
- The court held that Doe was not a “prevailing party” because the settlement lacked judicial imprimatur and did not effect a judicially sanctioned change in the parties’ legal relationship.
- The court applied Buckhannon’s prevailing-party standard to IDEA fee claims and rejected recovery based solely on a defendant’s voluntary change in conduct.

## Legal Principles

- Under Buckhannon, prevailing-party status generally requires an enforceable judgment on the merits or a court-ordered consent decree, reflecting a judicially sanctioned change in the parties’ legal relationship.
- A private settlement, without incorporation into an order or comparable official approval, does not confer prevailing-party status for fee-shifting purposes.
- IDEA’s fee-shifting provision uses “prevailing party” in a manner consistent with Buckhannon; policy arguments favoring settlement cannot supply prevailing-party status absent judicial or administrative imprimatur.

## Conclusion

Because Doe obtained relief solely through a private settlement lacking any court order, consent decree, or administrative merits decision, she did not qualify as a prevailing party under the IDEA and was not entitled to attorneys’ fees.


Doe v. Boston Pub. Sch., 358 F.3d 20 (1st Cir. 2004)