Whitney Ford Rodney Ford v. Long Beach Unified School District

Whitney Ford (“Whitney”) and her father, Rodney Ford (“Rodney”), appeal the district court’s order dismissing their request pursuant to the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. §§ 1400-1487 , for attorneys’ fees related to legal services provided by Whitney’s mother and Rodney’s wife, Tania Whiteleather. We have jurisdiction under 28 U.S.C. § 1291 and must address an issue of first impression in this circuit: Is a parent performing legal services for her own child entitled to attorneys’ fees pursuant to the IDEA? We hold that attorney-parents are not entitled to attorneys’ fees for the representation of their children in IDEA proceedings.

I

Whitney is a student in the Long Beach Unified School District (the “School District”) suffering from a series of anxiety problems. Whitney also experiences difficulty remembering dates or facts and completing written and mathematics assignments. These problems have constantly and severely affected her performance in school. The instant case arises out of a series of disputes over Whitney’s educational needs between Whitney, her father Rodney Ford, and her mother and attorney Tania L. Whiteleather on one side, and…