Keenan

In this appeal, we must determine the proper statute of limitations for an action arising under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. §§ 1400-1491 , challenging the decision of an administrative hearing officer following an impartial due process hearing. Because the IDEA does not specify a limitations period, we borrow the most analogous state' statute of limitations unless that statute would undermine the federal policies underlying the IDEA. Concluding that the most analogous state statute of limitations is Montana’s thirty-day limitations period for judicial review of administrative decisions, we adopt this statute and reverse and remand for the district court to dismiss the complaint as time-barred.

I.

In May 1987, while in kindergarten, D.L. was identified by the Livingston School District in Livingston, Montana, as' mildly speech impaired and thereby eligible for special education services as a disabled student. D.L.’s teachers subsequently noticed that he had hearing difficulties. He received a series of hearing evaluations over the next several years, partially at the School District’s expense and partially at his parents’ expense. Pursuant…