## Facts

- Thomas F. “Tommy” Smith III, a child with cerebral palsy and other disabilities, was placed by his Rhode Island school district in a special day program at a hospital.
- The Cumberland School Committee funded the placement until the Superintendent notified Tommy’s parents that the Committee would stop funding, asserting the state mental health agency was responsible.
- The parents pursued state administrative proceedings to challenge the funding termination.
- The parents also filed a federal action seeking declaratory and injunctive relief under state law, the Education of the Handicapped Act (EHA), § 504 of the Rehabilitation Act, and constitutional theories asserted through 42 U.S.C. § 1983.
- The federal district court resolved the dispute on state-law grounds, holding Tommy was entitled to a free appropriate special education at public expense, and did not reach the federal statutory or constitutional claims.
- Attorney’s fees were awarded against the local school committee by agreement; the parents also sought fees from state defendants for work performed in the administrative proceedings.
- The First Circuit reversed the fee award against the state defendants, reasoning the matter was essentially an EHA enforcement action and the EHA contained no attorney’s fee provision.

## Issues

1. Whether parents may recover attorney’s fees under 42 U.S.C. § 1988 based on substantial constitutional claims pleaded under 42 U.S.C. § 1983 when the dispute concerns denial of a free appropriate public education governed by the EHA, which lacks a fee provision.
2. Whether parents may recover attorney’s fees under § 505 of the Rehabilitation Act by asserting a § 504 claim where the relief sought is covered by the EHA’s remedial scheme.
3. Whether the EHA was intended to be the exclusive federal avenue for claims that a child with disabilities was denied a free appropriate public education, thereby foreclosing parallel fee-seeking routes.

## Decision

- The Supreme Court affirmed the First Circuit.
- The Court held the parents were not entitled to attorney’s fees under § 1988.
- The Court held the parents were not entitled to attorney’s fees under § 505 of the Rehabilitation Act.
- The Court concluded Congress intended the EHA to be the exclusive vehicle for claims seeking a free appropriate public education, preventing plaintiffs from using § 1983 or § 504 to obtain remedies (including fees) not provided by the EHA.
- The Court rejected fee recovery based on constitutional claims that were either unrelated to the ultimate merits relief obtained or would have required bypassing the EHA’s comprehensive process.

## Legal Principles

- Where Congress provides a detailed remedial framework for a specific class of claims (here, the EHA for free appropriate public education disputes), that scheme may be treated as exclusive and may preclude use of other statutes to obtain additional remedies.
- A plaintiff may not use § 1983 and § 1988 to secure attorney’s fees when the gravamen of the action is enforcement of EHA rights and the EHA omits a fee-shifting remedy.
- A plaintiff may not invoke § 504 and § 505 to obtain attorney’s fees when the § 504 claim effectively duplicates an EHA claim for denial of a free appropriate public education and would upset the EHA’s remedial structure.
- Attorney’s fees under § 1988 are not available for an entire proceeding merely because constitutional claims were pleaded; fees depend on the relationship between the claim producing success and the relief for which fees are sought.

## Conclusion

The Court treated the EHA’s comprehensive special-education scheme as the exclusive federal route for claims seeking a free appropriate public education and, because the EHA lacked a fee provision, barred attempts to recover attorney’s fees by repackaging the dispute under § 1983/§ 1988 or § 504/§ 505.


Smith v. Robinson, 468 U.S. 992 (1984)