New Legal Rule: IDEA Procedural Victory Confers Prevailing-Party Status for Fee Awards

Introduction

Micayla Augustyn v. Wall Township Board of Education is a 2025 Third Circuit decision that clarifies when a parent or student becomes a “prevailing party” under the Individuals with Disabilities Education Act (IDEA) and is entitled to recover attorneys’ fees. Petitioner-appellant Micayla Augustyn sought a due process hearing to challenge her school district’s alleged failures to implement her Individualized Education Plan (IEP), including the revision of her grades. After an Administrative Law Judge (ALJ) dismissed that procedural claim, Augustyn prevailed in the district court on summary judgment and secured a remand for the hearing she requested. The Board of Education challenged her status as a “prevailing party” and the scope of her fee award. The Third Circuit’s opinion reinforces that any statutory vindication—substantive or procedural—under IDEA can tip the scales for an award of fees, so long as the relief is enduring and judicially sanctioned.

Summary of the Judgment

The Third Circuit held by majority vote that:

Under IDEA, a party who vindicates a statutory right—substantive or procedural—is a prevailing party entitled to attorneys’ fees (citing Lackey v. Stinnie, 145 S. Ct. 659 (2025) and H.E. v. Walter D. Palmer Leadership Learning Partners Charter Sch., 873 F.3d 406 (3d Cir. 2017)).
Augustyn’s procedural victory—reversal of the ALJ’s dismissal and a summary-judgment order that she is entitled to a due process hearing on her grade-revision claim—constituted “permanent” relief that altered the legal relationship with the Board and conferred prevailing-party status.
The district court correctly found her a prevailing party and accepted her requested lodestar of $198,901.50. However, it improperly reduced that award by 90% to $23,079.10 on impermissible grounds, thereby warranting vacatur and remand.

Analysis

Precedents Cited

Lackey v. Stinnie (145 S. Ct. 659, 2025): Confirmed that any statutory victory—substantive or procedural—that produces enduring judicial relief can support prevailing-party status.
H.E. v. Walter D. Palmer Leadership Learning Partners Charter Sch. (873 F.3d 406 (3d Cir. 2017)): Held that a purely procedural IDEA win—securing a due process hearing—confers prevailing-party status, so long as the relief is not “temporary forward-looking injunctive relief.”
M.R. v. Ridley School District (868 F.3d 218 (3d Cir. 2017)): Distinguished preliminary injunctive relief from final relief for prevailing-party purposes.
Perdue v. Kenny A. (559 U.S. 542 (2010)) and City of Burlington v. Dague (505 U.S. 557 (1992)): Framework for calculating the “lodestar” (reasonable hours × reasonable rate) and permissible post-lodestar adjustments.
Loughner v. University of Pittsburgh (260 F.3d 173 (3d Cir. 2001)): The district court’s “positive and affirmative function” in fee fixing.

Legal Reasoning

The Third Circuit applied a two-step analysis to attorneys’ fees under 20 U.S.C. § 1415(i)(3). First, it determined prevailing-party status by asking whether Augustyn vindicated an IDEA right in a way that produced enduring judicial relief. The panel concluded that reversing the ALJ and ordering a due process hearing on her grade revision claim was “judicially sanctioned” and “materially altered the legal relationship” with the Board. Second, it examined the district court’s fee reduction. The “lodestar” of $198,901.50 was uncontested. But the district court slashed that number by 90%, citing the narrowness of relief and administrative-phase work. The Third Circuit held these were improper considerations:

Fees incurred in mediation and before the ALJ are recoverable when they are a “necessary precursor” to vindicating an IDEA right. The Board’s motion to dismiss below directly targeted Augustyn’s procedural entitlement to a hearing.
“Results obtained” can be considered only insofar as not already subsumed in the lodestar, and in any event the district court had already accepted the reasonableness of her counsel’s hours and rates.
Financial condition of the Board and speculation about the merits at the future hearing are impermissible factors under Third Circuit fee jurisprudence.

Impact

This decision cements three key points for IDEA litigants and lower courts:

Any substantive or procedural victory that produces “enduring” and “judicially sanctioned” relief qualifies for prevailing-party status, narrowing the scope for fee denials based on the nature of the underlying right.
District courts must calculate the lodestar and may adjust it only for factors not already subsumed—“rare circumstances” under Perdue—providing predictability in fee awards.
Fee reductions must rest on permissible Johnson factors (e.g., novelty, complexity, results), and not on the size or resources of the respondent or hypothetical success at future proceedings.

Complex Concepts Simplified

Prevailing Party: Under IDEA, you “win” not only by securing substantive relief (like compensatory education), but also by obtaining judicial recognition of a procedural right (like a due process hearing) if it changes the legal relationship permanently.
Lodestar: The basic fee calculation—hours reasonably spent multiplied by a reasonable hourly rate.
Post-Lodestar Adjustments: Allowed only for factors not already reflected in the lodestar (e.g., exceptionally high risk or novelty); “results obtained” is typically built into the reasonable‐hours assessment.
Judicially Sanctioned Relief: The relief must come from a court order that alters the parties’ legal rights—in contrast to an advisory or provisional finding.

Conclusion

The Third Circuit’s opinion in Augustyn v. Wall Township Board of Education sharpens the rule that any IDEA victory—procedural or substantive—that yields final, judicially imposed relief makes a party “prevailing” for fee purposes. It also reinforces strict limits on post-lodestar fee reductions, ensuring district courts do not reduce awards based on impermissible considerations such as unsuccessful administrative phases, hypothetical future success, or a losing party’s financial condition. Going forward, IDEA litigants can pursue procedural rights with confidence that vindicating those rights in federal court will, if enduring, carry with it the prospect of full fee recovery.