Counterclaim is not subject to IDEA statute of limitations

Jonathan H. v. The Souderton Area School Dist., 562 F.3d 527 (3rd Cir. 2009): School district's counterclaim, challenging award of compensatory education in IDEA action, was not “action” within meaning of limitations period applicable to party bringing civil action under IDEA, and, thus, counterclaim could be brought beyond IDEA's 90-day limitations period.