Lauren C. v. Lewisville Indep. Sch. Dist.
904 F.3d 363
| 5th Cir. | 2018Background
- Lauren C., a student in Lewisville ISD, contested that the District failed to identify autism in addition to intellectual disability; multiple district FIEs found intellectual disability but private doctors diagnosed autism.
- Parents requested and received an independent educational evaluation (IEE) that diagnosed autism but nonetheless endorsed the District’s IEP as appropriate; the ARD/IEP meetings incorporated many autism strategies though the District initially declined an autism label.
- Parents requested a due-process hearing (August 2014); the Special Education Hearing Officer (SEHO) (June 2015) found a Child Find violation (should have diagnosed autism) but also found the District’s FIE/IEE and IEP provided a FAPE and denied requested relief except to order convening the ARD to add autism to the IEP.
- The ARD convened (Sept. 2015), added autism eligibility and the autism supplement but made no changes to services; parents proposed no modifications.
- Lauren sued for attorneys’ fees as the “prevailing party” in federal court; the district court (June 2017) held the District complied with Child Find and provided a FAPE and denied fees. On appeal Lauren argued mootness (she aged out) and sought remand to assess fees based solely on the SEHO ruling.
- The Fifth Circuit held the merits (Child Find/FAPE) were moot when Lauren aged out, but the court nonetheless had jurisdiction to decide prevailing-party status and affirmed that Lauren was not a prevailing party for fee purposes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether claims re: Child Find and FAPE were moot after Lauren aged out | Lauren: she aged out at end of 2015–16, so merits claims were moot but fees still reviewable | LISD: merits moot but fee claim should not wipe out ability to challenge SEHO | Held: Merits claims were moot upon aging out, but fee entitlement is independent and reviewable |
| Whether the SEHO’s Child Find ruling conferred prevailing-party status for IDEA fees | Lauren: SEHO’s finding that District misdiagnosed her and the order to add autism made her prevailing party | LISD: the SEHO effected no material change to IEP or services, so no prevailing-party status | Held: No — SEHO’s order made no material alteration to legal relationship and did not change services |
| Whether a diagnostic label (adding autism) that produces no change in services furthers IDEA’s purposes | Lauren: changing diagnosis fosters IDEA goals and justifies fees | LISD: IDEA focuses on provision of appropriate education, not labels; no new services resulted | Held: Labels alone do not further IDEA’s purposes; relief that effects no new services is insufficient for prevailing-party status |
| Whether the SEHO’s order provided judicial imprimatur for fee award | Lauren: administrative order supplies imprimatur for fees | LISD: imprimatur exists but remedy must still materially alter relationship | Held: Imprimatur present, but absent material benefit/remedy, prevailing-party status fails |
Key Cases Cited
- Dallas Indep. Sch. Dist. v. Woody, 865 F.3d 303 (5th Cir. 2017) (IDEA requires provision of FAPE to eligible children)
- Endrew F. v. Douglas Cty. Sch. Dist., 137 S. Ct. 988 (2017) (IEP must be reasonably calculated to enable meaningful educational benefit)
- Richardson Indep. Sch. Dist. v. Michael Z., 580 F.3d 286 (5th Cir. 2009) (four-factor IDEA IEP adequacy test)
- Gary G. v. El Paso Indep. Sch. Dist., 632 F.3d 201 (5th Cir. 2011) (prevailing-party question reviewed de novo)
- Farrar v. Hobby, 506 U.S. 103 (1992) (prevailing-party inquiry focuses on material alteration of legal relationship)
- Salley v. St. Tammany Parish Sch. Bd., 57 F.3d 458 (5th Cir. 1995) (procedural victory alone may not confer prevailing-party status)
- Angela L. v. Pasadena Indep. Sch. Dist., 918 F.2d 1188 (5th Cir. 1990) (whether relief furthers IDEA determined by whether child receives services not previously requested)
- Doe v. Marshall, 622 F.2d 118 (5th Cir. 1980) (mootness does not automatically preclude consideration of attorneys’ fees)