Arlington Central School District Board of Education v. Murphy

Arlington Central School District Board of Education v. Murphy, legal case in which the U.S. Supreme Court on June 26, 2006, ruled (6–3) that parents who prevail in legal disputes with their school districts under the 1990 Individuals with Disabilities Education Act (IDEA) are not entitled to reimbursement for costs associated with hiring expert witnesses and consultants.

Background

Arlington Central School District Board of Education v. Murphy arose in 2002 after the parents of a student with disabilities prevailed in appellate court in a suit demanding that the Arlington Central School District Board of Education in New York state pay the cost of private-school tuition for their son for the years during which they litigated (ultimately successfully) against the school board for individualized services under the IDEA. The parents then asked the district court to award them the fees they had paid to an educational consultant who assisted them in their suit, in keeping with a provision of the IDEA that permitted a court to award “reasonable attorneys’ fees as part of the costs” to a prevailing party. The school board argued in response that it should not have to pay the consultant’s fees, because the provision authorized the recovery of attorneys’ fees only. The district court rejected that argument, holding that consultants’ fees could be treated as “costs” under the provision. The Court of Appeals for the Second Circuit affirmed, finding that “Congress intended to and did authorize the reimbursement of expert fees in IDEA actions.” Because other appellate courts had reached conflicting conclusions in similar cases, the Supreme Court agreed to resolve the question, and oral arguments were heard on April 19, 2006.

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Majority and dissenting opinions

In an opinion written by Justice Samuel A. Alito, the Supreme Court reversed the Second Circuit’s decision, holding that the recovery provision of the IDEA applied only to attorneys’ fees. The court found that, because the IDEA was enacted under the spending clause of the U.S. Constitution (Article I, Section 8, clause 1), states that receive federal funds to implement the IDEA must be given clear notice of any conditions on the acceptance of such funds, in keeping with the Supreme Court’s earlier ruling in Pennhurst State School and Hospital v. Halderman (1981). The recovery provision of the IDEA, however, “does not even hint that acceptance of IDEA funds makes a State responsible for reimbursing prevailing parents for services rendered by experts.” Moreover, the court pointed out that, although the IDEA contains provisions concerning how courts should calculate attorneys’ fees to ensure their reasonableness, Congress included no analogous language for expert witnesses and consultants.

In the course of its analysis, the court rejected the Second Circuit’s finding that the phrase “attorneys’ fees as part of the costs” should be understood to apply to the fees of expert witnesses and consultants because—as mentioned in a footnote to the Supreme Court’s decision in West Virginia University Hospitals v. Casey (1991)—the conference-committee report on the amendment that added the recovery provision to the IDEA stated that “the conferees intend that the term ‘attorneys’ fees as part of the costs’ include reasonable expenses and fees of expert witnesses.” The footnote in Casey, the court argued, “did not state that the Conference Committee Report set out the correct interpretation” of the provision, “much less that the Report was sufficient, despite the language of the statute, to provide the clear notice required under the Spending Clause.” Alito’s opinion was joined by Chief Justice John G. Roberts, Jr., and by Justices Anthony Kennedy, Antonin Scalia, and Clarence Thomas. Justice Ruth Bader Ginsburg filed an opinion concurring in part and concurring in the judgment.

In a dissenting opinion, Justice Stephen Breyer argued that Congress’s intent to include experts’ fees within the recoverable costs was clearly indicated both by the conference-committee report and by the fact that the amendment that added the recovery provision also directed the Government Accountability Office (GAO) to compile data on the fiscal impact of the recovery provision, including, for each of a representative sample of IDEA suits, “the number of hours spent by personnel, including attorneys and consultants” for the prevailing party. Breyer also contended that a broader interpretation of the recovery provision was in keeping with “the IDEA’s statutorily defined purposes.” Finally, he expressed concern that barring the recovery of fees for expert witnesses and consultants would have a chilling effect on parents seeking to advocate for the interests of their children. Breyer’s opinion was joined by Justices David Souter and John Paul Stevens. Souter also wrote a brief dissenting opinion.