Doe v. Boston Public Schools
United States Court of Appeals for the First Circuit
358 F.3d 20 (2004)
Jane Doe (plaintiff) sued Boston Public Schools (defendant) under the Individuals with Disabilities Education Act (IDEA), seeking placement in a private therapeutic day school. The parties privately negotiated a settlement in which Boston agreed to the placement, but the hearing officer refused Doe's request to have the agreement read into the record and signed. Doe then sought attorney's fees as a "prevailing party." The district court dismissed her fee claim, finding she was not a prevailing party.
Whether a plaintiff is a "prevailing party" entitled to attorney's fees where she achieved her desired result only through a private settlement lacking judicial approval or oversight.