child a FAPE, it was incumbent on them to bring that to the school’s attention via the available statutory mechanisms,” and on that basis denied relief. (J.A. at 179.) In this connection, the district court noted that“[s]chool boards must be given adequate notice of problems if they are to remedy them, and must be given sufficient time to respond to those problems before they can be held hable for failure to act.” (J.A. at 179-80 (citing Combs, 15 F.3d at 363-64).) Several of our sister circuits have concluded that an award of “compensatory education” — educational services ordered by the court to be provided prospectively to compensate for a past deficient program — may be “appropriate relief” under the IDEA. See, e.g., Ridgewood Bd. of Educ. v. N.E., 172 F.3d 238, 249 (3d Cir. 1999) (<HOLDING>); Board of Ed. of Oak Park & River Forest High
recognizing that family court cannot eliminate compensatory part of maintenance award recognizing appropriateness of compensatory education award and holding that plaintiff was entitled to recover compensatory education if she prevailed in her claim that she was denied a fape for several years holding that conduct must be beyond the fraud which supported compensatory damages to award punitive damages recognizing appropriateness in some circumstances of award of compensatory education beyond age 21 and remanding for determination of whether it should be awarded recognizing equitable nature of back pay award under age discrimination in employment act