Livingston School District Nos. 4 & 1 v. Keenan

FLETCHER, Circuit Judge:

In this appeal, we must determine the proper statute of limitations for an action arising under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. §§ 1400-1491, challenging the decision of an administrative hearing officer following an impartial due process hearing. Because the IDEA does not specify a limitations period, we borrow the most analogous state' statute of limitations unless that statute would undermine the federal policies underlying the IDEA. Concluding that the most analogous state statute of limitations is Montana’s thirty-day…