M. R. v. Ridley School District, 868 F.3d 218

E.R., a child with learning disabilities in Ridley School District, was placed in private school by her parents after IEP negotiations failed; an administrative hearing officer initially found Ridley’s IEPs inadequate.
Ridley appealed and the district and then this Court reversed the administrative ruling on the IEP merits, holding the proposed IEPs adequate.
While the IEP appeal proceeded (2009–2012), the administrative decision made the private placement E.R.’s “then-current educational placement,” triggering IDEA § 1415(j) “stay put” reimbursement obligations. Ridley refused to reimburse during the appeals process.
E.R.’s parents sued for reimbursement under the IDEA “stay put” provision; the district court and then this Court (Ridley IV) awarded retrospective reimbursement for the stay-put period. Ridley’s cert. petition was denied and reimbursement then occurred.
After obtaining reimbursement, the parents moved for attorneys’ fees under IDEA § 1415(i)(3)(B)(i); the district court denied fees, treating the reimbursement as interim/temporary relief that did not make them "prevailing parties."
The Third Circuit reversed: it held that court-ordered retrospective/compensatory relief enforcing a stay-put reimbursement obligation is merits-based relief that confers "prevailing party" status and entitles parents to fees; remanded to determine fee amount.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether parents who obtained court-ordered reimbursement for a child’s stay-put placement are "prevailing parties" eligible for attorneys’ fees under IDEA § 1415(i)(3)(B)(i)	Reimbursement enforces a procedural right under §1415(j); it is backward-looking, merits-based, independent of IEP merits, so parents prevailed and are entitled to fees	Reimbursement is merely interim/"stay put" relief (like preliminary injunctions) and therefore not merits-based; parents are not prevailing parties	Awarding retrospective/compensatory reimbursement under §1415(j) is merits-based and confers "prevailing party" status; remand for fee determination

Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598 (2001) (definition of "prevailing party" requires judicially sanctioned material alteration of legal relationship)
John T. ex rel. Paul T. v. Delaware County Intermediate Unit, 318 F.3d 545 (3d Cir. 2003) (preliminary educational injunctive relief not always merits-based for fee purposes)
J.O. ex rel. C.O. v. Orange Township Bd. of Education, 287 F.3d 267 (3d Cir. 2002) (temporary reinstatement order did not confer prevailing-party status)
Bagby v. Beal, 606 F.2d 411 (3d Cir. 1979) (procedural victory at a hearing can constitute prevailing-party success under § 1988)
People Against Police Violence v. City of Pittsburgh, 520 F.3d 226 (3d Cir. 2008) (injunction that provided enduring relief conferred prevailing-party status)
Ridley Sch. Dist. v. M.R. (Ridley II), 680 F.3d 260 (3d Cir. 2012) (appellate decision on the substantive IEP merits)
M.R. v. Ridley Sch. Dist. (Ridley IV), 744 F.3d 112 (3d Cir. 2014) (affirming district court that parents were entitled to stay-put reimbursement)
Drinker ex rel. Drinker v. Colonial School District, 78 F.3d 859 (3d Cir. 1996) (parents entitled to renew motion for attorneys’ fees after stay-put reimbursement)
P.N. ex rel. M.W. v. Clementon Bd. of Educ., 442 F.3d 848 (3d Cir. 2006) (reimbursement for supplemental services conferred prevailing-party status)