D.F. v. Collingswood Borough Board of Education, 694 F.3d 488

D.F. was a five-year-old kindergartner in 2008-2009; Collingswood adopted the Camden IEP in substantial part with the mother’s consent.
In January 2009, A.C. filed a due process petition alleging IDEA violations, later supplemented with a second petition; stay-put rights were triggered.
D.F. was placed in a regular classroom with pullout speech and counseling, but the Camden behavior plan allowing restraints was not implemented in Collingswood.
A one-to-one aide was provided in January 2009; as the year progressed, behavioral incidents increased and meetings addressed potential out-of-district placements.
In 2010, after multiple petitions and hearings, the ALJ ordered Archway as a placement; A.C. refused to send D.F. and moved to Georgia, raising mootness issues.
The District Court granted summary judgment for Collingswood, concluding mootness and denying compensatory education and attorney’s fees; the case was appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the move out of state mooted the compensatory education claims	Move did not moot compensatory education claims under IDEA	Out-of-state move renders claims moot	Not moot; compensatory education not extinguished by relocation
Whether D.F. is entitled to compensatory education for claims beyond the one-to-one aide period	Compensatory education for all alleged FAPE violations during Collingswood period	Only the one-to-one aide period potentially implicated	Remand required to determine full compensatory education scope
Whether D.F. was a prevailing party for attorneys’ fees	Filing petition and subsequent orders causally connected to relief obtained	No causal connection; district complied without litigation	Not a prevailing party; no award of fees

Lester H. v. Gilhool, 916 F.2d 865 (3d Cir. 1990) (compensatory education as remedy for denied FAPE)
Burlington Sch. Comm. v. Dep't of Educ., 471 U.S. 359 (Supreme Court 1985) (retroactive reimbursement as appropriate relief)
Miener ex rel. Miener v. State of Missouri, 800 F.2d 749 (8th Cir. 1986) (compensatory educational services as remedy)
Ridgewood Bd. of Educ. v. N.E. ex rel. M.E., 172 F.3d 238 (3d Cir. 1999) (FAPE entitlement not abridged by district's conduct; caution on standards)
Ferren C. v. Sch. Dist. of Phila., 612 F.3d 712 (3d Cir. 2010) (compensatory education relief forms and district obligations)
Pihl v. Mass. Dep’t. of Educ., 9 F.3d 184 (1st Cir. 1993) (remedies under IDEA; inter-district considerations)
J.O. ex rel. C.O. v. Orange Twp. Bd. of Educ., 287 F.3d 267 (3d Cir. 2002) (prevailing party and fee-shifting standards)
D.S. v. Bayonne Bd. of Educ., 602 F.3d 553 (3d Cir. 2010) (deference and standard of review in IDEA appeals)
Wheeler v. Towanda Area Sch. Dist., 950 F.2d 128 (3d Cir. 1991) (causation/catalyst framework for fees)
L.E. v. Ramsey Bd. of Educ., 435 F.3d 384 (3d Cir. 2006) (ability to review district court factual findings for clear error)