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 the Compton Unified School District liable for denying a minor student a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA) and affirmed the award of attorney’s fees to the plaintiffs. The court ruled 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 fee motion. Regarding the substantive claim, the court applied de novo review to legal questions and clear error review to factual findings, concluding that the California Office of Administrative Hearings had jurisdiction to determine student residency as it was intertwined with the IDEA violation. The court found that the school district violated the IDEA by summarily disenrolling the student without a formal revocation of her inter-district permit and failing to provide an Individualized Education Program (IEP) by the statutory deadline. The court rejected the district’s arguments that liability was negated because the employment-based permit technically expired due to the parent’s medical leaves or because another district held responsibility for the student during her hospitalization; the court reasoned that the denial of services resulted directly from the district’s procedural violations and its failure to identify the child as having a disability, which precluded other districts from assuming responsibility. On the issue of attorney’s fees, the court applied an abuse of discretion standard, noting that while fee awards must consider the degree of success, there is no precise formula for calculation. The court held that the district court did not abuse its discretion by awarding approximately $770,000 after applying a 30 percent reduction for limited success, as the plaintiffs achieved the most significant possible victory under the IDEA by proving the denial of a FAPE. Consequently, the judgment in favor of the plaintiffs stands, and the school district must pay the awarded fees.

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