SELYA, Circuit Judge.
After the district court denied Marc Adams' application for attorneys' fees on the ground that he had not prevailed in proceedings under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. §§ 1400-1485, Adams launched this appeal. We affirm.
I. BACKGROUND
In 1991, a New Hampshire state court sentenced Adams to 15-to-30 years in the state penitentiary for manslaughter. After Adams began serving his sentence...
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