PETTIES EX REL. MARTIN v. District of Columbia
398 U.S. App. D.C. 257
D.C. Cir.2011Background
- IDEA class action (1995) alleging DC underfunded private special education providers, threatening placements; court issued a 1995 preliminary injunction and ongoing payment orders.
- Special Master appointed in 1997 to manage transportation and payment disputes; later expanded to resolve provider disputes.
- OSSE and DCPS implemented new payment system under Education Reform Amendment Act of 2007; by 2009–2010 invoicing and disputes were largely resolved.
- DC filed Rule 60(b)(5) motion in 2009 arguing changed circumstances and durable compliance warranted vacation of injunction and payment orders; plaintiffs argued durable reforms were not yet tested and disputes mechanism needed testing.
- District court denied the motion in 2010, finding continued need to maintain status quo and disputing the extent of Horne v. Flores relevance; DC appealed seeking vacatur; this court remands for factual inquiry on changed circumstances and ongoing risk of harm.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 60(b)(5) relief was appropriate given changed circumstances and no ongoing federal-law violation. | Petties argues durable compliance and systemic reform render injunction unnecessary. | DC argues changed circumstances and a durable remedy support vacatur. | Remanded for district court factual determination on Rule 60(b)(5) relief. |
| Whether the changes constitute a durable remedy and reduce risk of imminent harm to plaintiffs. | Durable remedy not demonstrated; need dispute-resolution mechanism and testing of reforms. | Durable reforms implemented; imminent harm no longer at risk. | Remand to assess ongoing risk of harm and durability of remedies. |
| Whether the district court properly assessed the relevance of Horne v. Flores to a preliminary-injunction context. | Horne requires broader inquiry into ongoing violations and durable remedies. | Horne is distinguishable; focus on changed circumstances suffices. | Court acknowledges Horne guidance but remands for district-court fact-finding. |
| Whether an alternative dispute-resolution mechanism suffices to terminate judicial supervision. | Need tested mechanism replacing Special Master and a time-limited dispute process. | Adequate alternative forum exists (OAH/Superior Court); ongoing supervision unnecessary. | Remand to evaluate durability and adequacy of dispute-resolution framework. |
Key Cases Cited
- Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367 (1992) (flexible modification standard for institutional-reform decrees)
- Chaplaincy of Full Gospel Churches v. England, 454 F.3d 290 (D.C.Cir.2006) (flexible, broad inquiry for relief from injunctions in institutional reform)
- Heath v. De Courcy, 888 F.2d 1105 (6th Cir.1989) (public-policy considerations in injunctive relief)