Prevailing Party Status Under IDEA: Attorneys' Fees for Procedural Victories

Introduction

Micayla Augustyn v. Wall Township Board of Education (3rd Cir. 2025) addresses whether a student who vindicates a procedural right under the Individuals with Disabilities Education Act (IDEA) is a “prevailing party” entitled to attorneys’ fees, even if the right secured is procedural rather than substantive. Following an Administrative Law Judge’s dismissal of her due‐process claim and a successful appeal to the District Court, Augustyn obtained an order remanding her grade‐revision claim back to the IDEA hearing process. The Board of Education contested both her prevailing‐party status and the amount of attorneys’ fees awarded. On appeal, the Third Circuit reaffirmed that IDEA prevailing‐party status encompasses procedural victories and vacated a drastic fee reduction for misapplication of governing standards.

Summary of the Judgment

• The Third Circuit held that, under Lackey v. Stinnie (145 S. Ct. 659, 2025) and its own precedent in H.E. v. Walter D. Palmer (873 F.3d 406, 2017), a student who secures a procedural IDEA right (here, the right to a due‐process hearing on grade revision) is a “prevailing party” eligible for fees.

• The District Court had awarded Augustyn a lodestar of $198,901.50 but reduced it by over 80% to $23,079.10, deeming her success “extremely limited.”

• The Third Circuit determined that the lodestar calculation was correct but the reductions rested on impermissible factors—such as punishing Augustyn for losing before the ALJ, speculating about her hearing outcome, and considering the Board’s resources—warranting vacatur and remand to recalculate fees properly.

Analysis

Precedents Cited

• Lackey v. Stinnie, 145 S. Ct. 659 (2025) – Held that enforcing a statutory right under IDEA, whether procedural or substantive, confers prevailing‐party status when the relief is enduring and judicially sanctioned.
• H.E. v. Walter D. Palmer Leadership Learning Partners Charter Sch., 873 F.3d 406 (3d Cir. 2017) – Recognized that a procedural victory under IDEA (securing a due‐process hearing) establishes prevailing‐party status.
• M.R. v. Ridley School District, 868 F.3d 218 (3d Cir. 2017) – Distinguished temporary, forward‐looking relief (e.g., preliminary injunctions) from fees‐worthy victories under IDEA.
• Hensley v. Eckerhart, 461 U.S. 424 (1983) – Guided adjustments of the lodestar based on “results obtained” and warned against using fee awards to penalize counsel for unsuccessful claims when those claims relate to the same case.
• City of Burlington v. Dague, 505 U.S. 557 (1992) – Confirmed the lodestar formula (reasonable hours × reasonable rate) as the starting point for fee awards.

Legal Reasoning

1. Prevailing‐Party Status: The Court held that because IDEA’s fee provision applies to “any action or proceeding brought under” the statute, a plaintiff who successfully obtains the right to an IDEA due‐process hearing—even on a procedural ground—qualifies as a prevailing party. That principle flows from Lackey’s insistence that enforcement of an IDEA right, substantive or procedural, yields fee entitlement if the relief is “enduring” and “judicially sanctioned.”

2. Lodestar Calculation: The Third Circuit agreed that Augustyn’s counsel reasonably documented hours and rates, yielding a $198,901.50 lodestar. Under Perdue v. Kenny A. (559 U.S. 542, 1990), that figure carries a “strong presumption” of reasonableness and ordinarily should not be adjusted except in “rare circumstances.”

3. Improper Fee Reductions: The Court found the District Court’s 80-90% reduction abusive because it relied on:

• Punishing counsel for arguments before the ALJ—even though those arguments directly led to the successful appeal;
• Speculation about the Board’s financial status and Augustyn’s ultimate prospect of success on remand;
• Over-generalizing that procedural relief is worth less than substantive relief.

Such factors are not authorized by Hensley or IDEA’s fee-shifting framework.

4. Remand Instructions: The case returns to the District Court to (a) accept the full lodestar, (b) consider only proper Johnson factors (e.g., novelty, customary fees, results obtained), and (c) justify any deviation with specific findings. The District Court must also recalculate the “fees on fees” for this appeal.

Impact

• This decision cements that procedural victories under the IDEA—such as securing a due‐process hearing—carry equal weight to substantive victories for fee awards.

• It guides federal courts on the narrow circumstances that justify reducing a lodestar and warns against importing extraneous considerations (e.g., a plaintiff’s financial resources or the perceived value of the remedy).

• School districts can expect that unsuccessful defenses at the administrative level, when reversed on appeal, will generate compensable fees for parents’ counsel. Conversely, parents can rely on a strong presumption that fees will be awarded for successful IDEA appeals, even if the relief is procedural.

Complex Concepts Simplified

• IDEA Fee-Shifting: The statute lets a “prevailing party” recover attorneys’ fees when challenging a school district’s compliance. “Prevailing” means that a court grants final, enduring relief on the merits of an IDEA right—procedural or substantive.
• Lodestar: A fee-setting method multiplying reasonable hours by a reasonable hourly rate. It creates a baseline for fee awards.
• Johnson Factors: Twelve considerations—such as complexity, customary fees, results obtained—that courts may consult when adjusting the lodestar, but only if they were not already captured in the rate or hours.
• Due‐Process Hearing: An IDEA safeguard allowing parents to challenge any matter related to a child’s special‐education plan (IEP) before an impartial hearing officer.
• FAPE: The IDEA requires a Free Appropriate Public Education tailored to a student’s unique needs. Disputes over FAPE triggers procedural safeguards like mediation and due‐process hearings.

Conclusion

Micayla Augustyn v. Wall Township Board of Education reaffirms that IDEA’s fee provision protects parents and students who enforce their procedural rights. It underscores that fee awards must start with an accurate lodestar calculation and may only be reduced for factors properly considered under Hensley and its progeny. By curbing arbitrary reductions, the Third Circuit ensures that attorneys who secure IDEA remedies—procedural or substantive—are fairly compensated, bolstering access to counsel and the enforcement of special‐education rights nationwide.