School district’s obligations under the IDEA are triggered by residence, not by enrollment of the student.

DISTRICT OF COLUMBIA v. WEST (D.C. 3-30-2010) and D.S. v. DISTRICT OF COLUMBIA (D.C. 3-30-2010): In the first action, the district sought recovery of attorney fees from the attorneys for the parents, a claim which was rejected by the Court. Of interest, the Court found that a district’s obligations under the IDEA are triggered by residence, not by enrollment of the student. In the second action, the IHO dismissed the parent's complaint as frivolous because the parent challenged the recommendations of the MDT despite the fact that her child was not enrolled. As in the first case, the Court held that a district’s obligations under the IDEA are triggered by residence, not by enrollment of the student.