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U.S. Department of Education: Promoting Educational Excellence for all Americans
Statute: TITLE I / B / 615 / i / 3 / B / i / III

(III) to a prevailing State educational agency or local educational agency against the attorney of a parent, or against the parent, if the parent's complaint or subsequent cause of action was presented for any improper purpose, such as to harass, to cause unnecessary delay, or to needlessly increase the cost of litigation.