Seventh Circuit holds Buckhannon applies to IDEA
In Buckhannon Board. & Care Home v. W. Va. Dept. of Health and Human Resources, 532 U.S. 598(2001), a case involving attorney fee-shifting provisions of the Americans with Disabilities Act and the Fair Housing Amendments Act, the Supreme Court held that in order to be a “prevailing party” under those acts a litigant must obtain judicially-sanctioned relief such as a judgment on the merits or a consent decree. 532 U.S. at 603-604.