The Ninth Circuit, in P.N. v. Seattle School District, No. 1, held that a parent, who resolved her differences with the school district through a settlement agreement, which did not receive any judicial imprimatur, was not a prevailing party entitled to recover attorneys' fees under IDEA. This is not a new development in the law, but it underscores the necessity of getting any settlement agreement "so-ordered" by the Court. Otherwise, even if you gain benefits from the school district, you are going to have to pay your own attorney. This has been the law since Buckhannon Board & Care Home, Inc. v. West Virginia Dep't of Heath & Human Resources, and yet some people still screw it up.
The decision in P.N. can be found here.