## Facts

- Daniel Field, a high-school student classified as emotionally disturbed, received special-education services under the EHA.
- Daniel’s IEP placed him half-day at an alternative program and half-day at Haddonfield Memorial High School; his parents sought changes to his placement and services.
- In March 1989, Daniel and his parents filed an administrative due-process petition challenging his special-education placement; the parties resolved the dispute through a settlement that altered Daniel’s educational program.
- The parents later sought attorneys’ fees and costs for the 1989 proceeding, claiming prevailing-party status based on the settlement.
- After Daniel developed substance-abuse problems, he attended a substance-abuse treatment program; participation was required as a condition for him to remain in school.
- In March 1990, the parents filed a second administrative petition seeking an order requiring the district to pay for the treatment program.
- An ALJ ruled the treatment program was a “medical service,” making its cost the parents’ responsibility rather than the school district’s.
- The parents sought (1) attorneys’ fees for the first petition and (2) judicial review reversing the ALJ on the second petition; the parties filed cross-motions for summary judgment.

## Issues

1. Whether parents who obtained relief through an administrative settlement in an EHA due-process proceeding were “prevailing parties” entitled to attorneys’ fees and costs.
2. Whether a substance-abuse treatment program constituted a required educational placement/related service under the EHA, or an excluded “medical service” not payable by the school district.

## Decision

- The court held the parents were prevailing parties in the 1989 administrative proceeding and were entitled to reasonable attorneys’ fees and costs.
- The court affirmed the ALJ’s decision that the substance-abuse treatment program was a medical service, not an educationally required related service, and the district was not responsible for its cost.
- Summary judgment was granted for the parents on the fee claim arising from the first petition and for the school district on the claim challenging the ALJ decision from the second petition.

## Legal Principles

- Under the EHA fee-shifting provision, parents may be “prevailing parties” if they obtain meaningful relief that materially changes the parties’ legal relationship, including through an administrative settlement causally linked to the due-process filing.
- In determining whether a placement or program must be funded under the EHA, courts distinguish between services primarily educational in purpose (potentially reimbursable/required) and services primarily medical/therapeutic in purpose (generally excluded, even if educational benefits exist).
- A residential or therapeutic program is not chargeable to a school district when it primarily responds to medical, social, or emotional problems that are separable from the learning process rather than being educationally indispensable.
- In judicial review of EHA administrative decisions, the court applies independent review while giving due weight to the ALJ’s findings and upholds the decision if supported by a preponderance of the evidence.

## Conclusion

The court awarded attorneys’ fees to parents who secured material program changes through an administrative settlement, but upheld an ALJ determination that substance-abuse rehabilitation was a non-covered medical service for which the school district had no payment obligation under the EHA.


Field v. Haddonfield Bd. of Educ., 769 F. Supp. 1313 (D.N.J. 1991)