## Facts

- G.M., a 17-year-old student with learning disabilities, received special education services from the New Britain Board of Education.
- G.M.’s planning and placement team (PPT) developed and revised his individualized education program (IEP) and included school personnel and representatives supporting G.M.
- A service provider recommended shifting G.M.’s program toward transitional planning with community-based goals.
- G.M.’s advocate sought PPT adoption of a more community-based program and requested an independent educational evaluation at public expense; the Board declined to authorize the evaluation without a showing of necessity.
- The PPT later rejected implementing the proposed community-based curriculum.
- G.M.’s guardian requested an IDEA due process hearing challenging (1) the adequacy of the IEP, including rejection of a community-based program, and (2) refusal to fund an independent evaluation.
- During the administrative hearing, the parties stipulated that an independent evaluation would be conducted and that the Board would implement the evaluator’s recommendations.
- The evaluator recommended a program that substantially incorporated the previously rejected community-based curriculum; the parties stipulated to implement those recommendations.
- The hearing officer accepted the stipulation as the final decision in the administrative case.
- G.M. then sought attorney’s fees and costs in federal court under IDEA’s fee-shifting provision; the district court granted summary judgment for the Board, finding G.M. was not a prevailing party.

## Issues

1. Whether a student is a “prevailing party” under the IDEA when an administrative due process hearing ends in a stipulation accepted as the hearing officer’s final decision.
2. Whether prevailing-party status requires an express adjudicatory finding that the school district violated the IDEA.
3. Whether the stipulated administrative outcome produced a material alteration in the parties’ legal relationship sufficient to support a fee award.

## Decision

- The Second Circuit reversed the district court’s summary judgment for the Board and remanded.
- The court held that G.M. was a prevailing party in the IDEA administrative proceeding.
- The stipulation, accepted as the hearing officer’s final decision, provided enforceable relief that materially changed G.M.’s educational program.
- The court rejected the argument that settlement-based administrative relief cannot support prevailing-party status.
- The court also rejected the view that fees are unavailable absent an express finding of an IDEA violation.

## Legal Principles

- A party prevails for fee-shifting purposes by succeeding on a significant issue and obtaining some of the benefit sought, resulting in a material alteration of the legal relationship between the parties.
- Relief obtained through settlement or stipulation may confer prevailing-party status when it is embodied in an enforceable order carrying sufficient administrative imprimatur.
- Under the IDEA, a formal finding that the school district violated the statute is not required for prevailing-party status if the claimant secures substantial, nontechnical relief tied to the claims asserted.

## Conclusion

Because the hearing officer’s final decision adopted an enforceable stipulation providing an independent evaluation and implementing recommendations that substantially shifted G.M.’s program toward community-based services, G.M. obtained significant relief and qualified as a prevailing party eligible to seek attorney’s fees and costs under the IDEA.


G.M. ex rel. R.F. v. New Britain Bd. of Educ., 173 F.3d 77 (2d Cir. 1999)