P.N., Parent of T.N., a Minor v. Seattle School District, No. 1

P.N., plaintiff-appellant, filed an action under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq., to recover attorneys’ fees incurred in resolving a conflict with the Seattle School District (“SSD”) over her child’s education. The conflict was resolved by a settlement agreement signed only by the parties. The district court held that P.N. was not a prevailing party, and thus, not entitled to attorneys’ fees under the IDEA because the settlement agreement lacked any judicial imprimatur. We affirm. We hold, consistent with our own precedent and decisions by our sister circuits, that (a) the definition of “prevailing party” set forth by the Supreme Court in Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598, 600 , 121 S.Ct. 1835 , 149 L.Ed.2d 855 (2001), applies to the IDEA’S attorneys’ fees provision, (b) the determination that a parent is a prevailing party requires that there be some judicial sanction of the settlement agreement, and (c) there is no judicial imprimatur of the settlement agreement in this case.

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The IDEA seeks “to ensure that all children with disabilities have available to them a free…