Arlington Central School District Board of Education v. Murphy
In Arlington Central School District Board of Education v. Murphy, 548 U.S. 291 (2006), the Court similarly interpreted the fee-shifting provision of the Individuals with Disabilities Education Act, 20 U.S.C. 1415(i)(3)(B), which does not contain any version of the word incur, as simply adding reasonable attorneys fees incurred by prevailing parents to the list of costs that prevailing parents are otherwise entitled to recover. Id. at 297.