RIPPLE, Circuit Judge.
Richard and Mary Jodlowski, the parents of special education student Nicholas Jodlowski, brought this action to obtain attorney's fees pursuant to the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. §§ 1400 et seq. The district court held that the parents had prevailed in prior state administrative litigation and were therefore entitled to such fees under 20 U.S.C. § 1415(e)(4)(B). The district court accordingly...
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