Alief Independent School District v. C.C. Ex Rel. Kenneth C., 2013 U.S. App. LEXIS 6748

C.C. is a disabled minor enrolled in AISD in Texas.
On May 29, 2007, C.C.’s parents filed an IDEA administrative complaint against AISD with the Texas Education Agency.
AISD filed a hearing request and declaratory judgment; the parents voluntarily dismissed their complaint.
AISD proceeded with the hearing and presented unopposed evidence of IDEA compliance; the Hearing Officer ruled in AISD’s favor.
AISD then sued in district court under 20 U.S.C. § 1415(i)(2)(A) seeking attorneys’ fees for an alleged improper purpose.
The district court denied AISD’s fee request and later the Parents’ petition for their own attorneys’ fees; the Parents appeal challenging prevailing party status.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a losing IDEA party becomes prevailing by defeating a fee petition	Parents contend their defeat of AISD’s fee claim altered the legal relationship and constitutes prevailing status.	Defendants argue no meritorious relief or merits-based victory occurred; defeating a fee request is de minimis.	Not a prevailing party; affirmed.

El Paso Indep. Sch. Dist. v. Richard R., 591 F.3d 417 (5th Cir. 2009) (prevailing party standard under IDEA includes a remedy that alters legal relations and furthers IDEA)
Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (significant issues and merits-based relief required for fee eligibility)
Buckhannon Bd. & Care Home, Inc. v. West Virginia Dept. of Health & Human Resources, 532 U.S. 598 (U.S. 2001) (no prevailing party status without a genuine merits-based relief)
Texas State Teachers Ass’n v. Garland Indep. Sch. Dist., 489 U.S. 782 (U.S. 1989) (recovery premised on actual relief on the merits rather than mere litigation victories)
Prescott Unified School District v. R.P. ex rel. C.P., 631 F.3d 1117 (9th Cir. 2011) (defense of ancillary fee requests alone does not create prevailing party status)