Arlington Central School District Board of Education v. Murphy

PETITIONER: Arlington Central School District Board of Education
RESPONDENT: Pearl Murphy, et vir.
LOCATION: Board of Immigration Appeals

DOCKET NO.: 05-18
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Second Circuit

CITATION: 548 US 291 (2006)
GRANTED: Jan 06, 2006
ARGUED: Apr 19, 2006
DECIDED: Jun 26, 2006

ADVOCATES:
David B. Salmons - argued the cause for Petitioner
David C. Vladeck - argued the cause for Respondents
Raymond G. Kuntz - argued the cause for Petitioner

Facts of the case

Using the federal Individuals with Disabilities Education Act (IDEA), Joseph Murray's parents brought legal action to require the Arlington Central School District to pay for their son's private school tuition. After they prevailed, they sought reimbursement from the school district for fees they had paid to an educational consultant during the proceedings. They relied on an IDEA provision that allows courts to "award reasonable attorneys' fees as part of the costs" to prevailing parents. The school district argued that under Crawford Fitting Co. v. J.T. Gibbons, Inc., 482 U.S. 437, and West Virginia Univ. Hospitals, Inc. v. Casey, 499 U.S. 83, expert fees can only be reimbursed when there is explicit authorization in the statute. Because the statute made no specific mention of expert fees, the school district argued, the fees could not be reimbursed. The federal district court and Second Circuit Court of Appeals disagreed, however, finding that a Congressional Conference Committee Report and a footnote in Casey referencing it showed that IDEA was intended to authorize reimbursement of expert fees.

Question

Does the Individuals with Disabilities Education Act permit parents to recover fees they pay to experts during legal actions against school districts?

Media for Arlington Central School District Board of Education v. Murphy

Audio Transcription for Oral Argument - April 19, 2006 in Arlington Central School District Board of Education v. Murphy

Audio Transcription for Opinion Announcement - June 26, 2006 in Arlington Central School District Board of Education v. Murphy

John G. Roberts, Jr.:

Justice Alito has the opinion in 05-18, Arlington Central School District Board of Education versus Murphy.

Samuel A. Alito, Jr.:

This case comes to us on writ of certiorari to the Untied States Court of Appeals for the 2nd Circuit.

Respondents prevailed in an action on behalf of their son under the Individuals with Disabilities Education Act, or IDEA.

They then sought reimbursement for expert fees.

The District Court granted their request in part, and the Court of Appeals affirmed.

Noting two of our decisions, the Court of Appeals recognized that a fee-shifting provision will not be read to permit the recovery of expert fees without, “explicit statutory authority indicating that Congress intended for that sort of fee-shifting”.

Ultimately, though, the Court of Appeals was persuaded by a conference committee report and concluded that the IDEA authorized the award of expert fees.

In an opinion filed with the Clerk today, we reverse.

Our decision is guided by the fact that Congress enacted the IDEA pursuant to the spending clause.

Although Congress has broad power to set the terms on which it disperses federal money to the states, those conditions must be set out unambiguously.

The text of the IDEA provides that, “in any action or proceeding brought under this Section, the Court in its discursion may award reasonable attorneys’ fees as part of the costs to the parents of a child with a disability who is the prevailing party”.

While the Act provides for an award of reasonable attorneys’ fees, it does not even hint that acceptance of IDEA funds makes the state responsible for reimbursing expert fees.

Other provisions of the IDEA point in the same direction, and apart from the text, perhaps the strongest support for our interpretation is supplied by our decisions in the two cases I mentioned previously, Crawford Fitting Company versus J. T. Gibbons, Inc., and West Virginia University Hospitals v. Casey.

The reasoning of Crawford Fitting strongly supports the conclusion that the term “costs” here is defined by the categories of expenses enumerated in the cost statute, 28 USC Section 1920, which is strictly limited by Section 1821; and in Casey, we interpreted language in a fee-shifting provision that was virtually identical to the language here and concluded that it did not authorize the award of expert fees.

Moreover, the Court of Appeals’ reliance on a footnote in West Virginia University Hospital v. Casey, which commented on the conference committee report, suggesting that the IDEA provision here contemplated reimbursement for exert fees, is misplaced.

The footnote did not state that the conference committee report set out the correct interpretation of the provision here, much less that the report was sufficient, despite the language of the statute to provide the clear notice required.

Justice Ginsburg has filed an opinion concurring in part and concurring in judgment; Justice Souter has filed a dissenting opinion; Justice Breyer has filed a dissenting opinion in which Justices Stevens and Souter have joined.