PRECEDENTIAL


     UNITED STATES COURT OF APPEALS
           FOR THE THIRD CIRCUIT
                      ______


                   No. 17-1161
                      ______



                       RENA C.,
                          Appellant

                         v.

       COLONIAL SCHOOL DISTRICT
                  ______


  On Appeal from the United States District Court
      for the Eastern District of Pennsylvania
           (E.D. Pa. No. 2-15-cv-01914)
    District Judge: Honorable Timothy J. Savage
                      ______


             Argued October 23, 2017
Before: GREENAWAY JR., NYGAARD and FISHER,
               Circuit Judges.
                  (Filed: May 14, 2018)


David J. Berney, Esq.      [ARGUED]
1628 John F. Kennedy Boulevard
8 Penn Center Plaza, Suite 1000
Philadelphia, PA 19103
       Counsel for Appellant


Ellen M. Saideman, Esq.
7 Henry Drive
Barrington, RI 02806
      Counsel for Amicus Appellant


Karl A. Romberger, Jr., Esq.  [ARGUED]
Sweet Stevens Katz & Williams
331 East Butler Avenue
P.O. Box 5069
New Britain, PA 18901
      Counsel for Appellee


Emily J. Leader, Esq.
Pennsylvania School Boards Association
400 Bent Creek Boulevard
P.O. Box 2042
Mechanicsburg, PA 17055




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Sarah B. Dragotta, Esq.
Kevin M. McKenna, Esq.
Nicole D. Snyder, Esq.
Latsha Davis & McKenna
350 Eagleview Boulevard, Suite 100
Exton, PA 19341
       Counsel for Amicus Appellees


                            ______


                 OPINION OF THE COURT
                            ______



FISHER, Circuit Judge.
        This case arises out of a dispute under the Individuals
with Disabilities Education Act (“IDEA”). Under the IDEA,
when parents and school districts dispute a child’s
educational placement, a parent may file an administrative
due process complaint that can lead to an administrative
hearing. At least ten days before the dispute reaches a
hearing, the school district can extend a settlement offer to the
parent, referred to herein as a “ten-day offer.” If the matter
proceeds to a hearing and the parent is the prevailing party,
this ten-day offer becomes significant. A parent who is the
prevailing party may be awarded reasonable attorney’s fees
under the IDEA, but the ten-day offer allows a school district
to limit its exposure to such fees by limiting a parent’s
eligibility for attorney’s fees to only those fees accrued before
the time of the ten-day offer. If a parent rejects the ten-day




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offer, the parent may only receive attorney’s fees for work
done after the time of the offer if (1) the hearing leads to more
favorable relief than the offer included, or (2) the parent was
substantially justified in rejecting the offer.
        In the instant matter, Rena C., mother to student A.D.,
filed an administrative due process complaint against the
Colonial School District to determine an appropriate
placement for her daughter. In an effort to limit the accrual of
owed attorney’s fees, Colonial extended Rena C. what it
contends was a ten-day offer. Rena C. rejected the offer.
When the matter eventually proceeded to a hearing, an
administrative officer entered an order in favor of Rena C.,
ordering a private school placement for the student. As the
prevailing party, Rena C. then filed a claim for attorney’s fees
in the District Court. This appeal concerns whether or not
Colonial successfully limited Rena C.’s eligibility for
attorney’s fees with its offer. Because Rena C. was the
prevailing party, the District Court awarded her attorney’s
fees for work performed prior to the ten-day offer. However,
the District Court held that because she did not receive more
favorable relief and was not substantially justified in rejecting
the offer, she was not entitled to fees accrued after Colonial’s
offer. We disagree and hold that Rena C. was substantially
justified in rejecting Colonial School District’s offe