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Arlington Central School District Board of Education v. Murphy

Supreme Court of the United States · 2006 · Constitutional Law

Constitutional LawSpending ClauseStatutory InterpretationIDEAIDEAattorneys' feesexpert feescosts

Facts

Pearl and Theodore Murphy brought an action under the IDEA on behalf of their son, Joseph Murphy, seeking to require Arlington Central School District Board of Education to pay private school tuition for specified school years. After prevailing, they sought $29,350 for services performed by educational consultant Marilyn Arons during the IDEA proceedings. The district court reduced the amount to $8,650 and awarded that amount, and the Second Circuit affirmed. The question in the Supreme Court was whether the IDEA's fee-shifting provision allowing "reasonable attorneys' fees as part of the costs" also permits recovery of expert or consultant fees.

Issue

Does the IDEA provision stating that a court may award prevailing parents "reasonable attorneys' fees as part of the costs" authorize recovery of fees for services rendered by experts or consultants? In a Spending Clause statute, does the IDEA give States clear notice that accepting IDEA funds exposes them to liability for expert fees?

Rule

When Congress legislates under the Spending Clause, conditions attached to a State's acceptance of federal funds must be stated unambiguously so that States have clear notice of their obligations. The IDEA's authorization of "reasonable attorneys' fees as part of the costs" does not unambiguously authorize recovery of expert or consultant fees; "costs" is a term of art tied to the categories in 28 U.S.C. §1920, and expert witness fees are limited absent explicit statutory authorization.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, Maya Ortiz prevailed against the Lakeview County Schools Cooperative in a federal special-education action. She then sought $14,000 for a child-development specialist who evaluated her son, helped prepare the case, and testified at the hearing. The statute authorizes courts to award prevailing parents "reasonable attorneys' fees as part of the costs."

Should the court award the specialist's fees?

Explanation. The majority held that when Congress legislates under the Spending Clause, States must receive clear notice of funding conditions. The phrase "reasonable attorneys' fees as part of the costs" does not clearly authorize reimbursement for expert or consultant services. "Costs" is a term of art, not an open-ended reference to all litigation expenses, so the expert's fees are not recoverable. (Derived from Arlington Central School District Board of Education v. Murphy (2006).)