Crawford

MEMORANDUM **

The facts are known to the parties, and we will offer only a brief summary here. *186 Michael Crawford’s parents seek attorney’s fees after partial success in their dispute with San Dieguito School District. The parents opposed moving their son to a public high school, and challenged the district’s proposed accommodations for him. They did not achieve private placement following their administrative hearing, but they did win a transition plan to help Michael adjust to the new school. The District did not appeal the decision, and Michael now attends public school. Noting the parents’ limited success at the hearing, the district court declared the parents to be prevailing parties but awarded attorney’s fees at a forty-percent reduction. We find that the decision was not an abuse of discretion.

A party may be awarded fees even if he did not prevail on all issues, provided he obtained “some relief by the court.” Buckhannon Bd. & Care Home, Inc. v. West Virginia DHHR, 532 U.S. 598, 603 , 121 S.Ct. 1835 , 149 L.Ed.2d 855 (2001). The litigant must succeed on the merits of at least some claims, but need not obtain favorable judgment on all of them. In this case, the…