State of NH v. Adams, et al.

CourtDistrict Court, D. New Hampshire
DecidedJanuary 21, 1998
DocketCV-94-573-M
StatusPublished

This text of State of NH v. Adams, et al. (State of NH v. Adams, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of NH v. Adams, et al., (D.N.H. 1998).

Opinion

State of NH v . Adams, et a l . CV-94-573-M 01/21/98 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

State of New Hampshire Department of Education and Department of Corrections, Plaintiffs

v. Civil N o . 94-573-M

Marc Adams and Manchester School District, Defendants

O R D E R

In November of 1994, the New Hampshire Department of Education and the New Hampshire Department of Corrections (collectively, the "State"), filed this civil action, appealing a final administrative order issued pursuant to the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. § 1400, et seq. Defendants, the City of Manchester School District (the "School District") and Marc Adams, responded, seeking an order affirming both the preliminary and final administrative orders issued by the hearing officer.

In March of 1996, the court granted, in part, the State’s

motion for summary judgment and vacated the hearing officer’s

orders dated July 14 and October 6, 1994. The court then denied

the School District’s motion for summary judgment and Adams’

motion to dismiss. Subsequently, the parties resolved their

remaining differences and executed a settlement agreement. Claiming to have been the "prevailing party," Adams now moves for

an award of attorneys’ fees of approximately $100,000 and costs

of roughly $6,000.

Legal Standard

That portion of the IDEA under which Adams seeks attorneys’

fees provides:

In any action or proceeding brought under this subsection, the court, in its discretion, may award reasonable attorneys’ fees as part of the costs to the parents or guardian of a child or youth with a disability who is the prevailing party.

20 U.S.C. § 1415(e)(4)(B) (emphasis supplied). Such fees may be recovered for legal services provided at both the administrative and appellate levels. See Burpee v . Manchester School Dist., 661 F. Supp. 7 3 1 , 732 (D.N.H. 1987).

Although the Court of Appeals for the First Circuit has yet

to address the issue, several other circuits have held that the

phrase “prevailing party” has the same meaning under the IDEA as

it does under 42 U.S.C. § 1988. See, e.g., Combs v . School Bd.

of Rockingham County, 15 F.3d 3 5 7 , 360 (4th Cir. 1994) ("The term

‘prevailing party’ connotes the same general meaning under

§ 1415(e)(4)(B) and 42 U.S.C. § 1988, and cases interpreting both

sections apply the same principles to determine a plaintiff’s

entitlement to attorney’s fees.”); see also, Beard v . Teska, 31

F.3d 9 4 2 , 950 (10th Cir. 1994); Borengasser v . Arkansas State Bd.

2 of Educ., 996 F.2d 196, 199 (8th Cir. 1993); Krichinski v . Knox

County Schools, 963 F.2d 8 4 7 , 849 (6th Cir. 1992); Wheeler v .

Towanda Area School Dist., 950 F.2d 1 2 8 , 132 (3rd Cir. 1991);

Barlow-Gresham Union High School Dist., v . Mitchell, 940 F.2d

1280, 1284 (9th Cir. 1991); Angela L . v . Pasadena Indep. School

Dist., 918 F.2d 1188, 1193 (5th Cir. 1990).

In Farrar v . Hobby, 506 U.S. 103 (1992), the Supreme Court

described a "prevailing party," in the context of section 1988,

as follows:

[A] plaintiff "prevails" when actual relief on the merits of his claim materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff.

Id. at 111-12. (emphasis supplied). Accordingly, the

"touchstone of the prevailing party inquiry must be the material

alteration of the legal relationship of the parties in a manner

which Congress sought to promote in the fees statute." Texas

Teachers' Assoc. v . Garland School Dist., 489 U.S. 7 8 2 , 792-93

(1989). Success on any significant issue in the litigation which

achieves some of the benefit sought in bringing the action is

sufficient to qualify the recipient of the benefit as a

"prevailing party." Id. at 791-92 (citing Nadeau v . Helgemoe,

581 F.2d 275, 278-79 (1st Cir. 1978)).

3 If the court finds that an award of attorneys’ fees is

justified under the statute, it must then determine whether the

sum requested is reasonable. “Whether an award of attorney’s

fees is reasonable depends, in part, upon the degree of success

obtained by the plaintiff.” Urban v . Jefferson Cty. School

Dist., 89 F.3d 7 2 0 , 729 (10th Cir. 1996) (citing Hensley v .

Eckerhart, 461 U.S. 4 2 4 , 436 (1983)). In fact, there are

certainly circumstances under which a party who technically

prevails, “should receive no attorney’s fees at all.” Farrar, 506 U.S. at 115.

Background

The factual background to this litigation is set forth in detail in the court’s orders dated March 2 1 , 1996, and April 1 7 , 1997. The facts pertinent to the instant dispute are as follows.

In 1991 Adams pled guilty to a charge of manslaughter in connection with the death of a three year old girl. He was sentenced to a term of 15 to 30 years in the New Hampshire State Prison, where he is currently incarcerated. In February of 1992, Adams requested a due process hearing under the IDEA, asserting that he was entitled t o , but was not receiving, a free and appropriate public education in the prison. Prior to the due process hearing, however, the parties executed a settlement agreement, which the hearing officer then entered as his final order (the "Stipulated Order"). That order provided that the

4 School District (with input from the State) would develop an Individualized Education Plan ("IEP") for Adams for each year of a two-year compensatory education program and that the State would implement the IEP at the prison. Accordingly, all parties agreed that Adams was entitled t o , and would in fact receive, a free and appropriate public education while in the State’s custody.

Due to his own misbehavior and failure to comply with prison regulations, however, Adams was periodically confined to the prison’s Secure Housing Unit ("SHU" or “C-5”), which precluded the State from fully implementing the IEP as written. Adams and the School District then requested another due process hearing, at which they argued that the State had breached the terms of the Stipulated Order by failing to implement the IEP as written, notwithstanding the substantial changes in circumstances surrounding Adams’ incarceration. The State objected, claiming that Adams’ IEP had to be modified to take into account his periodic misbehavior and the necessity of housing him in SHU. The hearings officer framed the issues presented to him as follows:

Mar[c] A . seeks additional compensatory education and seeks an order from the Hearing Officer requiring the State Department of Corrections and the State Department of Education to implement the IEP as written.

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