The opinion of the court was delivered by: Ricardo M. Urbina United States District Judge
Re Document Nos.: 2, 3, 13
Re Document Nos.: 2, 3, 14
DENYING THE PLAINTIFFS'MOTIONS TO REMAND;GRANTING THE PLAINTIFFS'MOTIONS FOR LEAVE TO FILE AN AMENDED COMPLAINT;DENYING AS MOOT THE DEFENDANTS' MOTIONS TO DISMISS OR, IN THE ALTERNATIVE, FOR A MORE DEFINITE STATEMENT
This matter comes before the court on the motions to remand and the motions for leave to file amended complaints filed by the plaintiffs in the above-captioned matters. The plaintiffs, parents of minor children entitled to the protections of the Individuals with Disabilities Education Act ("IDEA"), commenced these substantively identical actions in the Superior Court of the District of Columbia, alleging that the defendants had violated the IDEA by failing to pay attorney's fees to which the plaintiffs were entitled. The defendants removed the actions to this court, and the plaintiffs have now filed motions to remand the cases to the Superior Court. The plaintiffs have also filed motions to amend their complaints. The defendants have moved in each case to dismiss or, in the alternative, for a more definite statement. Upon consideration of the parties' submissions, the court concludes that these actions were properly removed to this court and therefore denies the plaintiffs' motions to remand. In addition, the court concludes that the plaintiffs are entitled to amend their complaint. This ruling renders moot the defendants' motions to dismiss or, in the alternative, for a more definite statement.
II. FACTUAL & PROCEDURAL BACKGROUND
The plaintiffs are parents of minor children who are enrolled in the District of Columbia Public Schools and subject to the IDEA. Pls.' Mots. to Amend,*fn1 Ex. 1 ("Proposed Am. Compls.") ¶ 2. They allege as follows: at some point prior to September 2009, each complained that the defendants had failed to provide a Free and Appropriate Public Education ("FAPE") to their children as required under the IDEA. See id. ¶ 4. The parties participated in administrative due process hearings, after which Hearing Officer Determinations ("HOD") were issued granting the plaintiffs the relief they sought. Id. ¶ 5.
Following the issuance of the HODs, the plaintiffs filed actions in the Small Claims and Conciliation Branch of the Superior Court in August 2009, seeking to recover the attorney's fees they incurred in prosecuting their IDEA claims. See generally Compls. The defendants removed these actions to this court on September 18, 2009. See Notices of Removal. Shortly thereafter, the defendants filed motions to dismiss or, in the alternative, for a more definite statement, arguing that the complaints failed to contain a "short and plain statement of the claim" as required by Federal Rule of Civil Procedure 8(a), and that in the alternative, the complaints were so vague or ambiguous that the defendants could not reasonably prepare a response, in violation of Rule 12(e). See generally Defs.' Mots.
Rather than respond to the defendants' motions, the plaintiffs opposed the removal of these cases from the Superior Court, filing motions to remand on October 1, 2009.*fn2 See generally Pls.' Mots. to Remand. The plaintiffs then filed motions for leave to amend their complaints on January 19, 2010. See generally Pls.' Mots. to Amend. All of the aforementioned motions are now ripe for adjudication.
A. The Court Denies the Plaintiffs' Motions to Remand
As a preliminary matter, the plaintiffs argue that the court should remand these cases to the Superior Court because in their complaints, they assert simple contract claims rather than claims properly before this court. See generally Pls.' Mots. to Remand. The defendants respond that the plaintiffs' claims arise under the IDEA and were therefore properly removed to this court. See generally Defs.' Opp'ns to Pls.' Mots. to Remand.
A defendant may properly remove to federal court an action brought in a state court that arises under the Constitution, treaties, or laws of the United States. 28 U.S.C. § 1441(b); Hardin-Wright v. D.C. Water & Sewer Auth., 350 F. Supp. 2d 102, 104 (D.D.C. 2005) (citations omitted). "If, however, state law creates the cause of action, the court must determine whether the adjudication of those state law claims requires resolution of a substantial question of federal law,  because the mere presence of a federal issue in a state cause of action does not automatically confer federal-question jurisdiction." Id. at 104-05 (internal quotation marks and citations ...