10th Circuit Diagrams Sentences!!

I was sorta joking a few months ago when I pointed out how diagramming sentences was helpful in reading and understanding court cases.  Some of you may recall we had some fun with this when we Zoomed with the Dawg and we talked about our memories of diagrammed sentences in English class. Well, lo and behold, the 10th Circuit issued a decision recently in which the court not only talked about diagramming sentences, it did it!

The case is too boring to write about. It deals with the deadline for a school district to seek attorneys’ fees in an IDEA case.  Yawn.  The critical sentence that merited diagramming in the court’s opinion was the following, from the New Mexico Administrative Code:

Any action for attorneys fees must be filed within 30 days of the receipt of the last administrative decision.

That sounds pretty straight forward, but you know how lawyers are.  The parties disagreed about the meaning of the term “last administrative decision.”  To resolve the dispute, the court actually diagrammed this sentence along with another sentence from another provision in the Administrative Code.  Two diagrammed sentences in the published court opinion!   English teachers rejoice.  What you do matters.

The case is Board of Education of Gallup-McKinley County Schools v. Native American Disability Law Center, decided by the 10th Circuit on May 19, 2020. You can find it at 959 F.3d 1011 or 76 IDELR 174.