While IDEA has a default 90-day statute of limitations period for merits actions after the administrative decision if the relevant state has no explicit time limitation, it does not expressly provide a statute of limitations applicable to actions for attorneys’ fees. The District Court applied the 90-day statute of limitations for merits actions under Arkansas’s statutory framework for IDEA compliance, employing the legal principle that when a federal law has no statute of limitations, courts may borrow the most closely analogous state statute of limitations, unless doing so would frustrate the policy embodied in the federal law.
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