Brittany O. Ex Rel. L. v. Bentonville School District
683 F. App'x 556
| 8th Cir. | 2017Background
- Parent (Brittany O.), on behalf of her child L., pursued attorneys’ fees under the IDEA after prevailing in a state administrative proceeding; she sued the Bentonville School District in federal court.
- The IDEA authorizes courts to award reasonable attorneys’ fees to a prevailing parent but does not specify a limitations period for such fee claims.
- The district court borrowed an Arkansas statute (Ark. Code Ann. § 6-41-216(g)) and dismissed Parent’s fee claim as untimely because the hearing officer’s decision was dated November 25, 2013 and the complaint was filed March 5, 2014.
- Parent also brought substantive claims under 42 U.S.C. § 1983, the Rehabilitation Act, and the ADA arising from her child’s transfer during kindergarten to a day-treatment facility; she sought prospective injunctive relief against the State Commissioner.
- The Eighth Circuit reviewed choice-of-law for the limitations issue de novo, reversed dismissal of the IDEA fee claim as timely, and affirmed dismissal/summary judgment on the remaining federal-law claims and lack of standing for prospective relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a state limitations period for challenging an administrative IDEA decision governs a prevailing parent's federal action to recover IDEA attorneys’ fees, and when that limitations period begins to run | Parent argued the fee claim was timely because the limitations period should run from when the administrative decision became final after the 90-day window to appeal expired | District argued the limitations period began at the administrative decision date and Parent filed too late | Court held the limitations period for a fee claim does not begin until the 90-day period to challenge the administrative decision expires; Parent’s March 5 filing was timely |
| Whether Parent has standing to seek prospective injunctive relief against the Commissioner of the Arkansas Department of Education | Parent sought prospective relief to remedy future harms from the student’s placement transfer | Commissioner argued Parent lacked standing for prospective injunctive relief | Court held Parent lacked standing to seek prospective injunctive relief against the Commissioner |
| Whether summary judgment was proper on the § 1983, Rehabilitation Act, and ADA claims arising from the student’s transfer | Parent contended the transfer violated constitutional and disability anti-discrimination rights | District argued the claims lacked merit as to liability/relief | Court affirmed summary judgment for the District on these federal claims |
| Whether the district court should retain supplemental jurisdiction over the remaining state-law claim | Parent wanted the district court to decide the state-law claim as well | District and district court declined to exercise supplemental jurisdiction | Court affirmed the district court’s discretionary refusal to exercise supplemental jurisdiction |
Key Cases Cited
- Birmingham v. Omaha Sch. Dist., 220 F.3d 850 (8th Cir.) (guide for borrowing state statute of limitations when federal statute is silent)
- D.G. ex rel. LaNisha T. v. New Caney Indep. Sch. Dist., 806 F.3d 310 (5th Cir.) (limitations period for IDEA fee claims runs from expiration of appeal window)
- McCartney C. ex rel. Sara S. v. Herrin Cmty. Unit Sch. Dist. No. 4, 21 F.3d 173 (7th Cir.) (same approach to accrual of fee-claim limitations period)
- Hughes v. City of Cedar Rapids, 840 F.3d 987 (8th Cir.) (standing analysis for prospective injunctive relief reviewed de novo)
- Malone v. Hinman, 847 F.3d 949 (8th Cir.) (standard for de novo review of summary judgment on civil-rights and disability claims)
- Labickas v. Ark. State Univ., 78 F.3d 333 (8th Cir.) (district court discretion to decline supplemental jurisdiction)