concurring

in part and dissenting in part:

I respectfully dissent from the majority’s conclusions that (1) Park prevailed only on “minor” issues, and (2) the district court did not abuse its discretion in denying his attorney’s fees. The district court’s determination that Park was not the prevailing party was an abuse of discretion. See Shapiro v. Paradise Valley Unified Sch. Dist. No. 69, 374 F.3d 857 , 865 (9th Cir.2004). The majority mischaracterizes the issues on which Park prevailed as “minor” or “de minimis,” even while conceding that “the district court might have been within its discretion to award [Joseph] attorney’s fees.” Given the very narrow discretion a district court has to deny fees in claims brought under the Individuals with Disabilities Education Act (IDEA), the majority opinion ignores not only the letter of the law, but also the spirit and purpose of allowing attorney’s fees in cases where parents have been forced to litigate for years against school districts to get all or part of what the IDEA requires in the first place.

I.

When Joseph Park was three years old, he was diagnosed with a rare genetic defect known as 5p-syndrome (also known as Cri du Chat syndrome), which is caused by a deletion on chromosome 5. At that time, according to Joseph’s father, Joseph was able to speak only two words, and he was not yet walking. As a result of this disorder, Joseph has low muscle tone, suffers from speech and language delays and gross and fine motors skills delays, has difficulty in muscle training and coordination, and has deficient cognitive ability, limited verbal ability, and behavioral difficulties. Joseph has difficulty toilet training, is unable to control his drooling, and *1158 has difficulties buttoning and zipping his clothing and tying his shoes on his own.

Joseph attended elementary school within a special day class at the mainstream elementary school in the Magnolia District from the time he was three until June 2002, when he was twelve. In the spring of 2002, the Magnolia District conducted a triennial assessment of Joseph. The District concluded that for the 2001-2002 extended school year (ESY) and the 2002-2003 school year, Joseph should be placed in the Hope School, a special education school on a small campus that is separated from the other local schools. Joseph’s mother had concerns about the District’s assessment of Joseph, and after visiting the Hope School in May 2002, she decided that Hope was not appropriate for Joseph. In June 2002, Joseph’s mother exercised her right to request a due process hearing before the California Special Education Hearing Office. Because Joseph’s mother did not agree with the placement in the restrictive Hope School, Joseph spent that summer at a church-operated summer camp program. During this time, Joseph’s mother also arranged for Joseph to be evaluated by an independent speech-language therapist and an occupational therapist. In August 2002, the Anaheim District entered into a mediated interim agreement with Joseph. Pursuant to the agreement, Joseph was enrolled in a special day class for disabled children at the Lexington Junior High School, and the District formulated a plan for assessments of Joseph. The District’s assessments of Joseph took place during September and October 2002(and formed the basis for some of the claims Joseph Park presented before us). In November 2002, the District again concluded that the Hope School was an appropriate placement for Joseph, and it formulated Joseph’s full educational plan and goals.

The due process hearing commenced later that month. The Hearing Officer rendered his decision four months later, in March 2003, determining that because it was not the least restrictive environment available, the Hope School was indeed not an appropriate placement for Joseph, as Joseph’s mother had determined almost one year earlier, and holding that the District was required to supplement Joseph’s self-help goals and objectives. Joseph’s mother then exercised her right to pursue a civil action. In February 2004, the district court ordered the District to comply with the Hearing Officer’s order. As a result, the District was required to formulate new goals and objectives for Joseph, to compensate Joseph’s special education teacher for providing weeMy occupational therapy consultative services to Joseph, to undertake a new functional behavior assessment of Joseph, and to develop a behavior intervention plan for Joseph. Because of Joseph’s mother’s efforts in advocating for her son, Joseph obtained placement in a special day class at Lexington Junior High School. Instead of being cloistered in a segregated special education school, as the District had deemed acceptable, Joseph was able to attend a mainstream school and integrate into society as best he can, as is required by the IDEA. At the time of the due process hearing, Joseph was twelve years old. He is now sixteen and still fighting to obtain what is under the IDEA his statutory right.

II.

The IDEA is the primary federal legislation that supports special education and related services for children with disabilities. The IDEA is premised on the notion that “[ijmproving educational results for children with disabilities is an essential element of our national policy of ensuring equality of opportunity, full participation, *1159 independent living, and economic self-sufficiency for individuals with disabilities.” 20 U.S.C. § 1400 (c)(1). With that principle guiding the legislation, the IDEA seeks to “ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepare them for further education, employment, and independent living”; “to ensure that the rights of children with disabilities and parents of such children are protected”; and “to assist States, localities, educational service agencies, and Federal agencies to provide for the education of all children with disabilities.” Id. § 1400(d)(1).

Federal funding for state and local educational agencies under the IDEA is conditioned on the requirement that states provide a free appropriate public education (FAPE) to each disabled child. 20 U.S.C. § 1412 (a). When Congress enacted the IDEA’S predecessor, the Education for the Handicapped Act, in 1975, it authorized the federal government to pay up to 40% of the “excess” cost of educating a child with disabilities — the difference between the cost of educating a child with disabilities and the cost of educating a child without disabilities. See Congressional Research Service, Individuals with Disabilities Education Act (IDEA): Current Funding Trends, Feb. 11, 2005, at 8, available at http://digital.library. unt. edu/govdocs/crs//data/2005/upl-meta-crs6209/RL32085 — 2005Febll.pdf?PHPSES-SID=a8756a35fe20505c3d9cd827 b6100443. Despite the authorization, however, federal funding has never matched the 40% goal. In FY 1995, Congress appropriated only $2,322,915,000 to states for education of school-aged with disabilities— only 7.80% of estimated excess cost. Id. at 9 . Had Congress appropriated the amount it aspired to, the eligible states would have received $11,872,137,000. In FY 2002, at the time Joseph’s struggle to obtain an appropriate education began, Congress appropriated $7,512,533,000, some 15.45% of excess cost, rather than $19,446,407,000, which would have totaled 40% of excess cost. While the percentage of excess cost that the federal government has provided to eligible states has continually increased throughout the years, appropriations still do not reach even 20% of increased cost despite numerous congressional pleas for “full funding” of the 40% goal. See id.; see also IDEA Full Funding Act, S. 2185, 109th Cong. (2006); Mandatory IDEA Full Funding Compromise Act, H.R. 3145, 109th Cong. (2005); Mandatory IDEA Full Funding Compromise Act, H.R. 3802, 108th Cong. (2004); IDEA Full Funding Act of 2003, S. 939, 108th Cong. (2003); Full Funding for IDEA Now Act of 2003, H.R. 823, 108th Cong. (2003); Helping Children Succeed by Fully Funding the Individuals with Disability Education Act (IDEA), S. 466, 107th Cong. (2001); IDEA Full Funding Act of 2000, S. 2341,106th Cong. (2000).

Given the failure to reach the goals set out when the IDEA and its predecessor were enacted, it is no surprise that states and local school districts appear reluctant to provide truly appropriate public education for children with disabilities. At the time of the initiation of this action, school districts were being forced to pay for more than 85% of the cost of educating children with disabilities. At a time when general education in most school districts is increasingly underfunded, shouldering the burden of costly evaluations and education programs for disabled children grows more difficult every year. But the failure of Congress to reach 40% funding does not give states and school districts license to deny disabled children the education to which they are entitled. Under the IDEA, states receiving federal funding are required to provide every disabled child a free public education that is appropriate *1160 for the child’s needs, no matter how inadequate that federal funding may be. That the districts are strapped for cash does not entitle them to skimp on an individual’s education. Nor should it suggest to courts that they can decline to award attorney’s fees in cases such as this where the parents of disabled children clearly prevail on significant issues.

III.

For the purpose of attorney’s fees awards, a prevailing party is defined as “a party which ‘succeed[s] on any significant issue in litigation which achieves some of the benefit the parties sought in bringing the suit.’ ” Parents of Student W. v. Puyallup Sch. Dist., No. 3, 31 F.3d 1489, 1498 (9th Cir.1994) (alteration in original) (emphasis added) (quoting Plensley v. Eckerhart, 461 U.S. 424, 433 , 103 S.Ct. 1933 , 76 L.Ed.2d 40 (1983)). Park succeeded on several issues and achieved much of the benefit he sought in exercising his rights to a due process hearing and to bring a civil suit. The Hearing Officer determined, and the district court affirmed, that the District had denied Joseph a FAPE for the 2001-2002 extended school year (ESY) and for September 2002 through November 2002. To remedy the denial of a FAPE, the Hearing Officer required the District to provide compensatory education, which was awarded to Joseph in the form of services provided by his classroom teacher for thirty minutes per week for the remainder of the 2002-2003 school year and ESY, relief which the district court affirmed. In addition, the Hearing Officer found that although the goals and objectives the District formulated were generally appropriate for Joseph, the District needed to supplement the proposed IEP for Joseph that was in place beginning in November 2002 by adding self-help goals for buttoning, zipping, and toilet training. Finally, the Hearing Officer agreed with Joseph’s contention that the District had failed to offer Joseph an appropriate program at the Hope School and that the Hope School was not Joseph’s “least restrictive environment.” See 20 U.S.C. § 1412 (a)(5)(A) (conditioning state eligibility for federal funding on requirement that states educate disabled children with nondisabled children and remove disabled children “from the regular educational environment ... only when the nature or severity of the disability of a child is such that education in regular classes with the use of supplementary aids and services cannot be achieved satisfactorily”). Accordingly, the Hearing Officer called for implementation of a new functional behavior assessment (FBA) and behavioral intervention plan (BIP).

Park’s successes cannot be regarded as insufficient to render Park a “prevailing party,” even acknowledging that the District also prevailed on some issues. A party is “prevailing” where it can “point to a resolution of the dispute which changes the legal relationship between itself and the defendant.” Texas State Teachers Ass’n v. Garland Indep. Sch. Dist., 489 U.S. 782, 792 , 109 S.Ct. 1486 , 103 L.Ed.2d 866 (1989), quoted in Kletzelman v. Capistrano Unified Sch. Dist., 91 F.3d 68, 71 (9th Cir.1996); see also Texas State Teachers Ass’n, 489 U.S. at 792-93 , 109 S.Ct. 1486 (“The touchstone of the prevailing party inquiry must be the material alteration of the legal relationship of the parties.”). Park’s successes satisfy this standard. As a result of Park’s claim, the District was obligated to provide for consultative services by Joseph’s special education teacher, to formulate self-help goals, to undertake an FBA, and to implement a new BIP. Park’s litigation successes resulted in a significant change in the District’s legal obligations toward Park, which renders Park a prevailing party.

*1161 That Park failed to prevail on all of his claims does not preclude a determination that he was the prevailing party. A prevailing party need not succeed on all issues, but only on “ 1 any significant issue.’ ” Parents of Student W., 31 F.3d at 1498 (emphasis added) (quoting Hensley, 461 U.S. at 433 , 103 S.Ct. 1933 ). Moreover, a prevailing party need not achieve all of the relief claimed, but merely “some of the benefit the parties sought in bringing the suit.” Id. (internal quotation marks omitted); see also Shapiro, 374 F.3d at 865(“[I]t is also true that a party may be accorded prevailing party status by being awarded ‘some relief by the court,’ ” (quoting Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598, 603-04 , 121 S.Ct. 1835 , 149 L.Ed.2d 855 (2001))); Me. Sch. Admin. Dist. No. 35 v. Mr. & Mrs. R., 321 F.3d 9 , 15 (1st Cir.2003) (noting that a prevailing party must “succeed on the merits of a claim or defense,” but that “a party may be considered ‘prevailing’ even without obtaining a favorable final judgment on all (or even the most crucial) of her claims”), quoted in Shapiro, 374 F.3d at 865. Here, Park has clearly prevailed in obtaining some of the relief he sought.

Moreover, a prevailing party need not prevail on what may be considered the “central” issue of the case. In Texas State Teachers Ass’n , the Supreme Court found that the teachers’ union was the prevailing party in its § 1983 claim challenging a school board policy, even though the union had not been granted relief on what was identified by a divided panel of the Fifth Circuit Court of Appeals as the “main thrust” of the action. 1 489 U.S. at 787 , 109 S.Ct. 1486 (internal quotation marks omitted). Rejecting the “central issue” test for determining prevailing party status, the Court held that a party could be deemed “prevailing” even despite failure on a “central” issue as long as the party had prevailed on “any significant issue in litigation which achieve[d] some of the benefit the parties sought in bringing suit.” Id. at 792-93 , 109 S.Ct. 1486 (alteration in original) (internal quotation marks omitted). The Court noted that distinguishing between success on primary and secondary issues, or on central and tangential issues, is “essentially unhelpful” in defining a prevailing party. Thus, whether Park’s successes are on “central” or “primary” issues is irrelevant; the only salient question is whether the claims on which he prevailed are significant.

Of course, despite the general rule that the degree of success does not bear on the threshold question of eligibility for an attorney’s fees award, the Ninth Circuit has held that if success is insignificant, then a court may find that a party that succeeds on some claims is nonetheless not a prevailing party. Specifically, attorney’s fees may be properly denied “[wjhere the plaintiffs success on a legal claim can be characterized as purely technical or de minim-is.” Kletzelman, 91 F.3d at 71 (internal quotation marks omitted). Here, however, Park’s successes materially altered the education he receives. Because he chose to exercise his rights under the IDEA, the District was forced to reassess the objectives and plan for Joseph Park’s education and to provide for compensatory education to remedy its failure to provide a FAPE during several months of his education.

The issues on which Joseph prevailed are not technical or de minimis, as the majority would have it; rather, they go to the very essence of the IDEA. The determination by the Hearing Officer and the *1162 district court that Joseph was denied a FAPE the 2001-2002 ESY and for September 2002 through November 2002— even setting aside the other issues on which Joseph prevailed — is the most significant of successes possible under the IDEA. At the heart of the Act is the requirement that each disabled child receive a free appropriate public education that is tailored to his or her unique individual needs, see 20 U.S.C. § 1400 (d)(1)(A), and the necessity of providing education that is effective in “ensuring equality of opportunity, full participation, independent living, and economic self-sufficiency for individuals with disabilities,” see id. § 1400(c)(1), (d)(4). It is impossible to reconcile the majority’s conclusion that Joseph’s success was “minor” with the goals and statutory framework of the IDEA.

The majority’s decision to affirm the district court’s denial of fees, even though Joseph succeeded in proving that the District denied him a FAPE and has obtained significant relief, offers only discouragement to families with disabled children. Denial of attorney’s fees chills the exercise of their rights to pursue due process hearings and civil actions on similarly meritorious claims. It only encourages school districts to spend their resources fighting families who wish to vindicate their rights under the IDEA, rather than spending these resources where they should be spent — on providing public education to the disabled. Fee awards are generally the only mechanism through which disabled litigants with limited resources are able to vindicate their rights under the IDEA. The ability of plaintiffs to recover fees when they prove they have been denied their rights under the IDEA is central to the statutory framework of the Act. The fee provision of the IDEA, which originated in Congress’s enactment of the Handicapped Children’s Protection Act to overrule the Supreme Court holding in Smith v. Robinson, 468 U.S. 992 , 104 S.Ct. 3457 , 82 L.Ed.2d 746 (1984), that the Education for the Handicapped Act (the IDEA’S predecessor) did not allow attorney’s fees for prevailing parties, allows plaintiffs to act as private attorneys general to exercise their rights. This is precisely why “[a] district court’s discretion to deny a request for attorneys’ fees is narrow.” Kletzelman, 91 F.3d at 70 (citing Abu-Sahyun v. Palo Alto Unified Sch. Dist., 843 F.2d 1250 , 1252 (9th Cir.1988)). If a district court’s discretion to deny requests for attorneys’ fees were not so narrow, attorneys would be loath to take on any IDEA claim in which the client may be unable to pay for representation. Joseph had a valid claim, which the Hearing Officer recognized, and for which the district court affirmed Joseph merited relief. Lawyers will only bring these cases if they know that they will be compensated when they prevail. The majority’s decision to affirm the denial of attorney’s fees to a party which clearly prevailed on significant issues, despite the majority’s own acknowledgment that fees “might have been” within the discretion of the district court, will serve not only to deny Joseph Park the relief he deserves, but also to encourage school districts to violate the IDEA, while further discouraging families of disabled children from fighting for their rights under the IDEA.

. While Texas State Teachers Ass’n is a § 1983 case deciding a motion for attorney’s fees under § 1988, the Ninth Circuit has adopted its reasoning and result in IDEA cases. See, e.g., Kletzelman, 91 F.3d at 71 .