A.U.R.U. v. Washoe County School District

CourtDistrict Court, D. Nevada
DecidedFebruary 11, 2025
Docket3:23-cv-00528
StatusUnknown

This text of A.U.R.U. v. Washoe County School District (A.U.R.U. v. Washoe County School District) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
A.U.R.U. v. Washoe County School District, (D. Nev. 2025).

Opinion

2 UNITED STATES DISTRICT COURT

3 DISTRICT OF NEVADA

4 A.U.R.U, a minor, by and through Case No. 3:23-cv-00528-ART-CSD Parent and Legal Guardian and 5 individual, STEPHANY ULLOA, ORDER DENYING DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 6 Plaintiffs, v. 7 WASHOE COUNTY SCHOOL 8 DISTRICT,

9 Defendant. 10 Plaintiffs, A.U.R.U., a minor child, and his parent Stephany Ulloa, bring 11 this action against Defendant Washoe County School District (“District”) to 12 recover attorneys’ fees incurred during an administrative hearing pursuant to the 13 Individuals with Disabilities Education Act (“IDEA”). Before the Court is the 14 District’s motion for summary judgment, requesting that the Court deny Plaintiffs 15 any right to recovery attorneys’ fees in this matter. (ECF No. 21.) The parties 16 agreed to bifurcate issues between: (1) whether Plaintiffs are entitled to attorneys’ 17 fees; and (2) whether the attorneys’ fees requested are reasonable. (ECF Nos. 15 18 at 8-9; 22 at 5.) This order addresses only the first issue. Because the Court finds 19 that Plaintiffs are entitled to attorneys’ fees, the Court denies the District’s motion 20 for summary judgment (ECF No. 21). 21 I. BACKGROUND 22 On December 30, 2022, Plaintiffs filed a due process hearing request with 23 the Nevada Office of Administrative Hearings alleging that the District denied 24 A.U.R.U. a free appropriate public education (“FAPE”). (ECF No. 21-1.) After the 25 District responded, the parties participated in a resolution session. (ECF No. 21- 26 5 at 2-3; 22 at 2.) According to the District, the parties reached an agreement in 27 principle at the resolution session. (ECF No. 21-5 at 5, 9, 13, 27.) 28 On January 23, 2023, the District sent a settlement offer to Plaintiffs which 1 included the terms discussed at the resolution session. (ECF No. 21-9.) A few 2 days later, the District sent a follow-up email asking for a response by January 3 30 as to whether their summary of their agreement in principle at the resolution 4 session was accurate so that they could finalize a settlement agreement. (ECF 5 No. 21-10 at 2.) On February 1, Plaintiffs’ counsel responded with proposed edits 6 to the agreement, which the District objected to. (ECF No. 21-11 at 6, 15-17; 21- 7 1 at 5.) A week later, the District filed a motion to extend deadlines, which 8 Plaintiffs opposed. (ECF No. 21-12.) 9 On February 9, 2023, the District sent a second settlement offer to 10 Plaintiffs. (ECF No. 21-13.) The offer incorporated some of the requested edits. 11 The District also emailed A.U.R.U.’s parent a “prior written notice” summarizing 12 the remedies that the District had proposed. (ECF No. 21-14.) Two weeks later, 13 Plaintiffs’ counsel sent the District a letter stating that A.U.R.U.’s parent objected 14 to the prior written notice. (ECF No. 21-15 at 8.) 15 Before the administrative hearing, the District admitted to liability on the 16 merits of the case, including denial of FAPE. (ECF No. 21-21.) Accordingly, the 17 hearing officer (“HO”) limited the hearing to evidence regarding the appropriate 18 remedy. (Id. at 3-5.) After a two-day hearing in March 2023, the HO issued a 19 decision ordering remedies for the District’s denial of FAPE. (ECF No. 21-25 at 20 21-24.) The HO ordered a series of remedies including evaluations, compensatory 21 education, staff training, provision of records, and school-home contact. (Id. at 22 21-24.) Neither party appealed the ruling. (ECF No. 22 at 9.) 23 In April 2023, Plaintiffs’ counsel sent a letter to the District with an invoice 24 for attorneys’ fees. (ECF No. 21-29 at 7-19.) The District’s counsel responded that 25 they would not be paying attorneys’ fees. (Id. at 2.) Plaintiffs’ counsel then filed a 26 complaint for attorneys’ fees in state court, which the court dismissed for lack of 27 jurisdiction. (ECF No. 21-30.) 28 In October 2023, Plaintiffs filed the complaint in the instant case seeking 1 attorneys’ fees and costs of approximately $50,000. (ECF No. 1.) At a hearing 2 before Magistrate Judge Craig S. Denney, the parties agreed to bifurcation. (ECF 3 No. 17.) In March 2024, the District filed this motion for summary judgment. 4 (ECF No. 21.) Parties have not yet filed motions on the second issue. 5 II. LEGAL STANDARD 6 The IDEA provides that “the court, in its discretion, may award reasonable 7 attorneys’ fees as part of the costs to a prevailing party who is the parent of a 8 child with a disability.” 20 U.S.C. § 1415(i)(3)(B)(i). In order for a court to award 9 attorneys’ fees, the parent must (1) be a prevailing party and (2) seek reasonable 10 attorneys’ fees. Aguirre v. Los Angeles Unified Sch. Dist., 461 F.3d 1114, 1117 11 (9th Cir. 2006). 12 There are certain circumstances under which attorneys’ fees and related 13 costs may be prohibited. Attorneys’ fees and costs may not be awarded for 14 services performed subsequent to a written settlement offer if: 15 (I) the offer is made [] at any time more than 10 days before the proceeding begins; 16 (II) the offer is not accepted within 10 days; and 17 (III) the court or administrative hearing officer finds that the relief finally obtained by the parents is not more favorable to the parents than the offer 18 of settlement. 19 20 U.S.C. § 1415(i)(3)(D)(i)(I)–(III); Beauchamp v. Anaheim Union High Sch. Dist., 20 816 F.3d 1216, 1220–21 (9th Cir. 2016). “Notwithstanding subparagraph (D), an 21 award of attorneys’ fees and related costs may be made to a parent who is the 22 prevailing party and who was substantially justified in rejecting the settlement 23 offer.” Id. § 1415(i)(3)(E). 24 III. DISCUSSION 25 The District argues that Plaintiffs’ requested attorneys’ fees should be 26 denied or significantly reduced because Plaintiffs were not substantially justified 27 in rejecting the District’s settlement offer, unreasonably protracted litigation, and 28 achieved only de minimis success. (ECF No. 21.) Plaintiffs respond that they are 1 entitled to reasonable attorney’s fees for the period both before and after the 2 settlement offer because the relief finally obtained was more favorable than the 3 settlement offer, and they did not unreasonably protract litigation. (ECF No. 22.) 4 To determine whether Plaintiffs are entitled to attorneys’ fees under IDEA, 5 the Court first addresses whether Plaintiffs were the prevailing party at the 6 administrative hearing, then addresses whether the statutory bar to attorneys’ 7 fees applies. Because the parties have bifurcated issues, the question of whether 8 Plaintiffs’ unreasonably protracted litigation is more appropriate to address on 9 the second issue of whether the requested attorneys’ fees are reasonable. 10 A. Whether Plaintiffs were the Prevailing Party 11 “A prevailing party is one who succeeds on any significant issue in litigation 12 which achieves some of the benefit the parties sought in bringing the suit.” Van 13 Duyn ex rel. Van Duyn v. Baker Sch. Dist. 5J, 502 F.3d 811, 825 (9th Cir. 2007) 14 (internal quotation marks and citation omitted). “The success must materially 15 alter the parties’ legal relationship, cannot be de minimis and must be causally 16 linked to the litigation brought.” Id. In Van Duyn, the court found that the plaintiff 17 was the prevailing party where the administrative law judge ruled in his favor on 18 only one out of eleven issues raised. Id.

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A.U.R.U. v. Washoe County School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/auru-v-washoe-county-school-district-nvd-2025.