S.B. v. Idaho State Board of Education, et al.,

MEMORANDUM DECISION AND ORDER - 1
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
S.B., Parent of a child with a disability,
Plaintiff,
v.
IDAHO STATE BOARD OF
EDUCATION; IDAHO DEPARTMENT
OF EDUCATION,
Defendants.
Case No. 1:25-cv-00183-DCN
MEMORANDUM DECISION AND
ORDER
I. INTRODUCTION
Before the Court is Defendants Idaho State Department of Education (“ISDE”) and
Idaho State Board of Education’s (“ISBE”) (collectively the “State Education Defendants”)
Motion for Attorney Fees Against Counsel. Dkt. 17. Plaintiff’s counsel, Kristian Beckett,
responded (Dkt. 18), and ISDE and ISBE replied (Dkt. 19).
Having reviewed the record and briefs, the Court finds that the facts and legal
arguments are adequately presented. Accordingly, in the interest of avoiding further delay,
and because the Court finds the decisional process would not be significantly aided by oral
argument, the Court will address the motion without oral argument. Dist. Idaho Loc. Civ.
R. 7.1(d)(1)(B). For the reasons outlined below, the Court DENIES the State Educational
Defendants’ Motion for Attorney Fees Against Counsel.
II. BACKGROUND
The underlying controversy for this case was S.B.’s Individuals with Disabilities
Education Act (“IDEA”) claim which the Court dismissed with prejudice on February, 18,
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2026, and judgment was entered the following day. Dkt. 15; Dkt. 16. The case was
dismissed in favor of the State Educational Defendants, making them the prevailing parties
here.
The State Educational Defendants believe this case was frivolous, unreasonable,
and/or without foundation, and was brought for the improper purpose of raising litigation
costs. Additionally, the State Educational Defendants allege that S.B.’s counsel, Kristian
Beckett, has a pattern of filing meritless IDEA suits against state actors. See generally Dkts.
17, 19.
Based on that belief, the State Educational Defendants filed a motion for attorney’s
fees specifically against Beckett..
III. LEGAL STANDARD
Federal Rule of Civil Procedure 54 permits a party to file a motion for attorney fees.
It requires that a party “specify the judgment and the statute, rule, or other grounds entitling
the movant to the award” and “state the amount sought or provide a fair estimate of it.”
Fed. R. Civ. P. 54(d)(2)(B).
IDEA allows fee awards to prevailing parties. 20 U.S.C. § 1415(i)(3)(B). That statue
provides that “[i]n any action or proceeding brought under this section, the court, in its
discretion, may award reasonable attorneys’ fees as part of the costs” against a parent’s
legal counsel who files: (1) a complaint or subsequent cause of action that is “frivolous,
unreasonable, or without foundation,” continues to litigate after the litigation “clearly
became frivolous, unreasonable, or without foundation,” or (3) files a complaint . . . for an
“improper purpose.” Id.
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IV. DISCUSSION
“Attorney’s fees in civil rights cases should only be awarded to a defendant in
exceptional circumstances.” Barry v. Fowler, 902 F.2d 770 (9th Cir. 1990). And generally,
the standard for awarding attorney’s fees under IDEA is equivalent to stating the underlying
action was “wholly without merit.” Galen v. Cty. of Los Angeles, 477 F.3d 652, 666 (9th
Cir. 2007). The Court does not find the underlying action meets this high standard here,
and so no attorney’s fees will be awarded.
The Court does not think this case is as simple as State Educational Defendant’s
suggest. The Court’s prior decision analyzed the parties’ arguments for many pages,
reflecting the reality that the case was not completely frivolous. Dkt. 15, at 4–7. Moreover,
just because a party fails, or is likely to fail, on his or her claims, such does not
automatically mean the claims are wholly without merit.
There are also relevant policy reasons for denying attorney’s fees in this type of case
where the rights of disabled children are at stake. The Court should be reluctant to award
attorney’s fees against plaintiffs in IDEA cases lest such sanctions result in a chilling effect
on the public within the district. If plaintiffs are afraid of attorney’s fees, they might not
bring suit to enforce their rights if they think they may lose their case.
The Court does, however, take notice of the pattern alleged by the State Educational
Defendants of cases filed by plaintiff’s counsel for other clients regarding IDEA suits in
Idaho. While the Court does not think this alleged pattern is enough to warrant fees at this
time, Mr. Beckett should take care to pursue his client’s interests zealously, but also
reasonably. While here, the claims were not wholly without merit, they were borderline.
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The Court held it lacked jurisdiction because the matter was moot. Dkt. 15, at 7. A similar
claim with similar facts in the future that ends the same way may be found without merit,
especially after plaintiff’s counsel has knowledge that the claim will fail for mootness.
V. CONCLUSION
Exercising its discretion, the Court determines this case was not wholly without
merit. In other words, it was not frivolous, unreasonable, or without foundation, or brought
for improper purpose. For that reason, the Court declines to award attorney fees.
VI. ORDER
1. 	State Educational Defendants’ Motion for Attorney Fee Against Counsel (Dkt. 17)
is DENIED.
May 1, 2026
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