Case: A.H. v. Hedalen
6:25-cv-00020 | U.S. District Court for the District of Montana
Filed Date: Feb. 27, 2025
Closed Date: Aug. 13, 2025
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Case Summary
This is a case challenging Montana's alleged failure to provide education to students with disabilities aged 19 to 21. On February 27, 2025, two minors by and through their parents filed a putative class action lawsuit in the United States District Court for the District of Montana against the Governor and Superintendent of Public Instruction of Montana. The minor plaintiffs were seventeen and eighteen years old and each had cognitive disabilities. Represented by Disability Rights Montana, the Barbara McDowell Social Justice Center, and private counsel, the plaintiffs alleged that Montana violated the Individuals with Disabilities Education Act's (IDEA) requirements related to public education for students with disabilities. Specifically, the plaintiffs claimed that the state did not provide free appropriate public education (FAPE) to students with disabilities who were between 19 and 21 years old, even though it provided free education to other students in that age group. Further, the plaintiffs alleged that Montana administrative rules (Mont. Admin. R. § 10.55.805) required school districts to award high school diplomas to students with disabilities who completed the goals in their Individualized Education Programs (IEPs) even if those goals did not meet the state's standard graduation requirements. The plaintiffs contended that this violated the IDEA, and that awarding students diplomas in these situations prevented them from receiving free education beyond the age of 18.
The plaintiffs sought injunctive and declaratory relief, as well as attorneys' fees. The plaintiffs proposed a class of
All individuals who turned 19 within four years before the filing of this action or will turn 19 during the pendency of this action who are eligible or were eligible for a FAPE under the IDEA by any school district subject to the supervision and control of the [Montana Office of Public Instruction] and who, but for their granting of a diploma pursuant to Mont. Admin. R. § 10.55.805 or their turning 19, would otherwise qualify or would have qualified for a FAPE because they have not or had not yet earned a regular high school diploma.
District Judge Dana L. Christensen was assigned to the case.
On August 13, 2025, an order closing the case and judgment was entered by the Court. The parties jointly moved for entry of judgment pursuant to the terms of Defendants’ accepted offer of judgment. The Court ordered the Clerk to close the case and enter the judgment pursuant to the terms of Defendants’ accepted offer. The judgment set forth a process for the parties to negotiate fees and costs, extended the deadline for filing a fee petition if negotiations failed, and included a detailed timeline with contingencies. A.H. by & through L.H. v. Hedalen, No. CV 25–20–H–DLC, 2025 WL 2336473 (D. Mont. Aug. 13, 2025)
On October 3, 2025 the Court entered an amended Judgement based on the Parties’ Joint Motion to Enter Judgment pursuant to Defendant’s accepted Offer of Judgment. Defendants stipulated that Mont. Admin R. §10.55.805(4) violates the IDEA to the extent that it allows a school district to terminate special education services for students who have not earned a regular high school diploma or reached the age of 22. The Parties also reached an agreement on Defendants’ payment of Plaintiff’s attorneys’ fees and costs accrued to date. Within 30 days of this Court order, the Defendants will pay $55,000 to the “Disability Rights Montana Trust Account” which will satisfy attorneys’ fees and costs to the Plaintiffs.
The case is settled and closed.
Summary Authors
Isabel Bysiewicz (3/27/2025)
Ana Lopez (2/7/2026)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69687509/parties/ah-v-hedalen/
Christensen, Dana Lewis (Montana)
Goldin, Tal M. (Montana)
Hartman, Gerald (Montana)
Jenkins, James D (Montana)
Kim, Jason (Montana)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/69687509/ah-v-hedalen/
Last updated July 8, 2026, 5:29 a.m.
Docket for: A.H. v. Hedalen
Case Details
State / Territory:
Case Type(s):
Key Dates
Filing Date: Feb. 27, 2025
Closing Date: Aug. 13, 2025
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A putative class of students with disabilities in Montana who were denied free education from the ages of 19 to 21.
Plaintiff Type(s):
Attorney Organizations:
Disability Rights Education & Defense Fund (DREDF)
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Pending
Defendants
State
State of Montana
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Indv. w/ Disab. Educ. Act (IDEA), Educ. of All Handcpd. Children Act , 20 U.S.C. § 1400
Other Dockets:
District of Montana 6:25-cv-00020
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Sought:
Relief Granted:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Content of Injunction:
Implement complaint/dispute resolution process
Amount Defendant Pays: 55000.00
Issues
General/Misc.:
Disability and Disability Rights:
Intellectual/developmental disability, unspecified
Discrimination Basis:
Disability (inc. reasonable accommodations)
Case Summary of A.H. v. Hedalen, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/46225/ (last updated 2/7/2026).