## Facts

- Robert T., a child with cerebral palsy, was eligible for special education and related services under the Individuals with Disabilities Education Act (IDEA).
- His parents sought a full-time instructional assistant to support his participation in a regular classroom; the local school district refused.
- After an administrative due process proceeding, an administrative law judge (ALJ) ruled that neither IDEA nor Iowa law required a full-time aide.
- The parents sued in federal court against the local school entities and the Iowa Department of Education (Department).
- The Department supported affirmance of the ALJ’s ruling in district court.
- The district court reversed the ALJ on state-law grounds, ordered the aide, and awarded attorney’s fees to the parents as prevailing parties under IDEA.
- In a prior appeal, the Eighth Circuit held the local defendants and the Department violated IDEA and remanded for attorney’s-fee determinations.
- On remand, the district court required the Department to pay a portion of the parents’ attorney’s fees; the Department appealed that allocation.

## Issues

1. Whether the parents were “prevailing parties” against the Iowa Department of Education for purposes of IDEA’s attorney’s-fee provision.
2. Whether, and to what extent, the Department could be assessed attorney’s fees for phases of the dispute where it had limited involvement or exposure.

## Decision

- The Eighth Circuit affirmed that the parents were prevailing parties as to the Department.
- The court held that the prior appellate ruling finding the Department violated IDEA constituted a judicially sanctioned material alteration in the parties’ legal relationship.
- The court limited and clarified the Department’s fee liability, requiring fees to be allocated to work reasonably attributable to establishing or enforcing relief against the Department, not to unrelated or Department-remote portions of the case.

## Legal Principles

- Under IDEA fee shifting, a party “prevails” when it obtains a judicially sanctioned, material alteration of the legal relationship between the parties.
- A state educational agency may be liable for attorney’s fees when it is adjudicated to have violated IDEA, given its responsibility for statewide IDEA compliance.
- Fee awards must be tied to work reasonably expended to obtain the relief that supports prevailing-party status against the particular defendant; allocation may be required where multiple defendants or phases of proceedings are involved.
- Success initially obtained on state-law grounds does not preclude IDEA fee shifting if an IDEA violation is later adjudicated and supports the prevailing-party determination.

## Conclusion

The Eighth Circuit held that an adjudicated IDEA violation by a state education department can support prevailing-party status against the state agency, but attorney’s fees must be allocated so the agency pays only for work fairly connected to establishing or enforcing relief against it.


John & Leigh T. v. Iowa Dep't of Educ., 258 F.3d 860 (8th Cir. 2001)