Case Explained: P.H., ET AL. V. COMPTON UNIFIED SCHOOL DISTRICT, ET AL.

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-14

Docket: 5:21-cv-00219-DMG-SSC

The Ninth Circuit affirmed the district court’s judgment holding that the Compton Unified School District (CUSD) denied a student a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1400 et seq., and affirmed the award of attorney’s fees to the plaintiffs. The court applied de novo review to questions of law and mixed questions of law and fact, clear error review to factual findings, and abuse of discretion review to the fee award. The court held that it had jurisdiction over both the merits appeal and the fee appeal because the district court entered a final judgment on fees while the merits appeal was pending, thereby mooting any objection regarding the timing of the filing. Regarding the merits, the court ruled that the California Office of Administrative Hearings properly exercised jurisdiction over residency issues intertwined with the IDEA claim. The court found CUSD liable for denying FAPE because it summarily disenrolled the student and failed to provide an Individualized Education Program (IEP) despite a valid inter-district permit remaining in effect. The court rejected CUSD’s arguments that liability was negated by the student’s medical leaves or hospitalization, noting that the IDEA deadline for providing services had passed before the student could be identified as having a disability, and no other district bore responsibility for an unidentified student. Furthermore, the court determined the district court did not abuse its discretion in awarding attorney’s fees; although plaintiffs sought over $1.5 million, the court applied only a 30 percent reduction for limited success rather than the 70 percent reduction requested by CUSD, as the plaintiffs achieved the most significant possible victory under the IDEA by proving the denial of FAPE. As a result of this decision, the district court’s orders finding an IDEA violation and awarding approximately $770,000 in attorney’s fees remain in full force and effect, requiring CUSD to comply with the underlying administrative order and pay the awarded legal costs.

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