A.R. v. New York City Department of Education
United States Court of Appeals for the Second Circuit
407 F.3d 65 (2005)
- Written by Carolyn Strutton, JD
Facts
A number of parents (plaintiffs) brought administrative complaints against the New York City Department of Education (the DOE) (defendant) for alleged violations of their disabled children’s rights under the Individuals with Disabilities Education Act (IDEA). The claims arose in different parts of the DOE’s region, which lay within the jurisdiction of two different federal district courts. The parents prevailed in their administrative claims and attempted to recover attorneys’ fees during the administrative process, as allowed under the IDEA. The DOE refused to pay, claiming that the claimed amounts were unreasonable under the provisions of the act. The parents filed complaints in one of the federal district courts, claiming that they had been denied attorneys’ fees that they were entitled to receive under the IDEA. The district court held that the claimed attorneys’ fees were reasonable, based on the community standard of attorneys’ fees claimed in that district. The DOE appealed, arguing that the district court had applied the wrong community standard in its calculation of the reasonableness of the requested attorneys’ fees and should instead have applied a standard based on the entire region served by the DOE. The court of appeals consolidated the cases.
Rule of Law
Issue
Holding and Reasoning (Sack, J.)
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