John T. v. Iowa Department of Education

John and Leigh T. (parents) (plaintiffs) had a son named Robert who was diagnosed with cerebral palsy. Robert was considered disabled under the Individuals with Disabilities Education Act (IDEA), and his parents requested that the local school district (defendant) provide an instructional assistant full-time for Robert. The school district denied the request, and the parents appealed to an administrative-law judge (ALJ). The ALJ found that the IDEA and state law did not require the school district to provide Robert with an assistant. The parents appealed to federal district court and listed both the school district and the Iowa Department of Education (department) (defendant) as defendants. The department filed a brief urging the court to affirm the ALJ’s decision. The district court reversed the ALJ’s ruling, finding that state law required the school district to provide Robert with an assistant but failing to resolve the IDEA claim. The parents requested attorney’s fees, and the district court granted the request, holding that because the parents succeeded on their state-law claim, they were considered prevailing parties under the IDEA. The school district and the department appealed to the Eighth Circuit, which found that the school district and the department violated the IDEA and remanded the case for fee decisions. On remand, the district court held the department liable for part of the parents’ attorney’s fees because the Eighth Circuit had found that the school district and the department collectively violated the IDEA, making the parents the prevailing party. The department appealed.