R.P. Ex Rel. C.P. v. Prescott Unified School District
631 F.3d 1117
| 9th Cir. | 2011Background
- C.P., autistic, received an IEP and related services in Prescott Unified School District from 2003-04 through 2005-06.
- Parents alleged the district deprived C.P. of a FAPE under IDEA; district court upheld the IEP and dismissed non-IDEA claims as untimely or unfounded.
- District court awarded the district about $140,000 in attorney's fees and costs against the parents and their counsel.
- The court allowed an amendment window but denied adding new, substantially different claims after ruling on the IDEA claim.
- Appellants contended the district failed to tailor the IEP, relied on non-peer-reviewed methods, and lacked objective data; the district argued the IEPs were reasonably calculated to provide educational benefit and measurable goals existed.
- Court held the IDEA claim was not frivolous and the district abused its discretion in ruling on non-IDEA claims and in fee-shifting determinations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| IDEA compliance in 2004-05 and 2005-06 | C.P.'s IEP failed to address his needs. | IEPs were tailored, progress measured, and reasonably beneficial. | District complied with IDEA; no FAPE denial. |
| IEP team composition and reliability of methods | IEP team lacked autism expert; used inappropriate methods. | Team properly constituted; methods like ABA/DTT were appropriate and evidence-based. | No error; team composition and methods acceptable under IDEA. |
| Evidence of progress and data collection | Goals lacked objective data; progress was not adequately measured. | IEPs contained measurable goals; progress was documented in reports. | IEPs included measurable goals; progress supported district's compliance. |
| Amendment of non-IDEA claims after IDEA ruling | Should be allowed to amend to assert ADA/§504 claims. | Amendment was untimely and substantially different from original claims. | District court did not abuse discretion in denying leave to amend. |
| Attorney's fees under IDEA § 1415(i)(3)(B)(i) | Compensatory education remedies could justify fees; claims not frivolous. | Suits lacked foundation; fees appropriate due to frivolousness or improper purpose. | Fees awarded against parents were reversed in part; the court erred in applying fee-shifting standards; compensatory education recognized as remedy, but herein limitations applied. |
Key Cases Cited
- N.B. v. Hellgate Elementary Sch. Dist., 541 F.3d 1202 (9th Cir. 2008) (IDEA funds contingent on compliance with goals and procedures; educational benefit requirement)
- Bd. of Educ. of the Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (U.S. Supreme Court, 1982) (basic FAPE standard and educational benefit framework)
- J.L. v. Mercer Island Sch. Dist., 592 F.3d 938 (9th Cir. 2010) (review de novo of IDEA compliance; factual findings reviewed for clear error)
- J.W. ex rel. J.E.W. v. Fresno Unified Sch. Dist., 626 F.3d 431 (9th Cir. 2010) (IDEA IEP adequacy and individualized assessment standards)
- Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (U.S. Supreme Court, 1978) (standard for awarding fees to prevailing defendants; frivolousness)
- Bruno's Restaurant, 13 F.3d 285 (9th Cir. 1993) (post hoc reasoning prohibition in fee awards under Christiansburg framework)
- Park, ex rel. Park v. Anaheim Union High Sch. Dist., 464 F.3d 1025 (9th Cir. 2006) (remedies and compensatory education as potential relief)
- Witte v. Clark Cnty. Sch. Dist., 197 F.3d 1271 (9th Cir. 1999) (damages not available under IDEA; limitations on monetary remedies)
- Reid ex rel. Reid v. Dist. of Columbia, 401 F.3d 516 (D.C. Cir. 2005) (compensatory education concept as remedy)