Smith v. Robinson

Background

Tommy is an eight-year-old child with cerebral palsy whose local school stopped paying for his out-of-district program after state officials said another state agency should pay. His parents pursued the state administrative process, then sued in federal court relying on state law, the federal Education of the Handicapped Act (EHA), the Rehabilitation Act (§504), and constitutional claims for due process and equal protection. The District Court ordered the local school to pay and awarded attorney’s fees; the First Circuit reversed the fee awards.

Reasoning

The central question was whether families can recover lawyers’ fees under general civil-rights laws when their claim is essentially one to enforce the EHA. The Court held that, where the EHA plainly covers a handicapped child’s claim to a free appropriate public education, Congress intended that the EHA’s detailed administrative-and-judicial process be the exclusive route. Because the parents’ successful relief fell within the EHA, overlapping claims under §504 or the federal civil-rights statute (§1983) could not be used to obtain attorney’s fees under §1988 or §505.

Real world impact

The decision means families enforcing special-education rights that are covered by the EHA are less likely to collect attorney’s fees under broader civil-rights laws, so they must rely more on the EHA’s administrative process and its remedies. The ruling is narrow: it does not decide situations where the EHA is unavailable or where §504 clearly provides greater relief.

Dissents or concurrances

Justice Brennan (joined by Marshall and Stevens) dissented, arguing Congress and enforcing agencies intended §504 and §1983 to remain available and that families should have a chance to seek fee awards under those laws.