Smith v. Robinson
Annotate this Case
468 U.S. 992 (1984)
U.S. Supreme Court
Smith v. Robinson, 468 U.S. 992 (1984)
Smith v. Robinson
Argued March 28, 1984
Decided July 5, 1984
468 U.S. 992
When the Superintendent of Schools in Cumberland, R.I., informed petitioner parents of petitioner child, who suffers from cerebral palsy and other handicaps, that the School Committee no longer would fund the child's placement in a special educational program, the parents, in addition to appealing the Superintendent's decision to the School Committee and thereafter through the state administrative process, filed an action in Federal District Court against the School Committee and, subsequently, against certain state school officials. They asserted, at various points in the proceedings, claims for declaratory and injunctive relief based on state law, on the Education of the Handicapped Act (EHA), on § 504 of the Rehabilitation Act of 1973, and, with respect to certain federal constitutional claims, on 42 U.S.C. § 1983. The District Court held that the child was entitled, as a matter of state law, to a free appropriate special education paid for by the School Committee, and that it was therefore unnecessary and improper to reach petitioners' federal statutory and constitutional claims. By agreement between the parties, the court awarded attorney's fees against the School Committee. Petitioners then requested attorney's fees against the state defendants. The District Court held that petitioners were entitled to such fees for the hours spent in the state administrative process both before and after the date the state defendants were named as parties, reasoning that, because petitioners were required to exhaust their EHA remedies before asserting their § 1983 and § 504 claims, they were entitled to fees for those procedures. The Court of Appeals reversed, holding that, since the action and relief granted fell within the reach of the EHA, which establishes a comprehensive federal-state scheme for the provision of special education to handicapped children but does not provide for attorney's fees, the District Court had to look to 42 U.S.C. § 1988 and § 505 of the Rehabilitation Act for such fees. The Court of Appeals concluded that, even if the unaddressed § 1983 claims were substantial enough to support federal jurisdiction so as generally to warrant an award of attorney's fees, nevertheless, given the comprehensiveness of the EHA, Congress could not have intended its omission of attorney's fees relief in that statute to
be rectified by recourse to § 1988. The court disposed of the Rehabilitation Act basis for attorney's fees for similar reasons.
1. Petitioners were not entitled to attorney's fees under § 1988. Pp. 468 U. S. 1006-1016.
(a) The fact that petitioners prevailed on their initial claim that the School Committee violated due process by refusing to grant petitioners a full hearing before terminating funding of petitioner child's special education program does not, by itself, entitle petitioners to attorney's fees for the subsequent administrative and judicial proceedings. That due process claim was entirely separate from the claims made in the subsequent proceedings, and was not sufficiently related to petitioners' ultimate success to support an award of fees for the entire proceeding. Pp. 468 U. S. 1008-1009.
(b) As to petitioners' claim that the child was being discriminated against on the basis of his handicapped condition, in violation of the Equal Protection Clause of the Fourteenth Amendment, it is apparent that Congress intended the EHA to be the exclusive avenue through which such a claim can be pursued. The EHA is a comprehensive scheme to aid the States in complying with their constitutional obligations to provide public education for the handicapped. Allowing a plaintiff to circumvent the EHA's administrative remedies by relying on § 1983 as a remedy for a substantial equal protection claim would be inconsistent with that scheme. Pp. 468 U. S. 1009-1013.
(c) Even if petitioners' due process challenge to the partiality of the state hearing officer who reviewed the School Committee's decision might be maintained as an independent challenge, petitioners are not entitled to attorney's fees for such claim. That claim had no bearing on the substantive claim, on which petitioners prevailed, that the School Committee, as a matter of state and federal law, was required to pay for petitioner child's education. Where petitioners presented different claims for different relief, based on different facts and legal theories, and prevailed only on a nonfee claim, they are not entitled to a fee award simply because the other claim was a constitutional claim that could be asserted through § 1983. Pp. 468 U. S. 1013-1016.
2. Nor were petitioners entitled to attorney's fees under § 505 of the Rehabilitation Act. Congress struck a careful balance in the EHA between clarifying and making enforceable the rights of handicapped children to a free appropriate public education and endeavoring to relieve the financial burden imposed on the agencies responsible to guarantee those rights. It could not have intended a handicapped child to upset that balance by relying on § 504 for otherwise unavailable damages or for
an award of attorney's fees. Where, as here, whatever remedy might be provided under § 504 -- which prevents discrimination on the basis of a handicap in any program receiving federal financial assistance -- is provided with more clarity and precision under the EHA, a plaintiff may not circumvent or enlarge on the remedies available under the EHA by resort to § 504. Pp. 468 U. S. 1016-1021.
703 F.2d 4, affirmed.
BLACKMUN, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, POWELL, REHNQUIST, and O'CONNOR, JJ., joined. BRENNAN, J., filed a dissenting opinion, in which MARSHALL and STEVENS, JJ., joined, post, p. 468 U. S. 1021.
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