The Third Circuit held that the entry of a “Decision Approving Settlement” in an Individuals with Disabilities Education Act (IDEA) dispute satisfies the jurisdictional prerequisite to an appeal of an administrative IDEA determination under 20 U.S.C. § 1415(i). The parties purportedly entered into a settlement agreement, which an administrative law judge (ALJ) approved. Appellants then filed a complaint in the District Court. The complaint alleged that Appellants did not knowingly and voluntarily enter into the agreement. They sought relief under the IDEA, the New Jersey Declaratory Judgment Act to declare the settlement void, and the New Jersey Declaratory Judgment and Civil Rights Acts to declare the attorney fee waiver void. The Board moved to dismiss the complaint. The District Court dismissed the matter without prejudice for lack of subject matter jurisdiction. The Third Circuit reversed and concluded that to the extent Appellants’ complaint challenged the basis for the ALJ’s final order, it was an appealable order from which jurisdiction was proper in the District Court. To the extent the remainder of Appellants’ claims addressed the validity of the settlement agreement based on New Jersey contract law, the Third Circuit permitted the District Court to exercise its discretion to consider whether supplemental jurisdiction was appropriate.
