In the case of Smith et al. v. Robinson, Rhode Island Associate Commissioner of Education, et al., 1983, the Supreme Court ruled that parents of children with disabilities could not seek attorney's fees under Section 504 of the Rehabilitation Act when they were already granted relief under a more specific law - The Individuals with Disabilities Education Act (IDEA). The plaintiffs in this case were parents who had successfully sued their school district for failing to provide an appropriate education for their disabled child as required by IDEA and sought compensation for legal costs through Section 504. However, the court held that since IDEA was a more specific statute designed to address educational needs of disabled students and did not explicitly authorize awarding attorney's fees to prevailing parties, such awards could not be obtained via other laws like Section 504.

In the dissenting opinion for Smith et al. v. Robinson, Justice Thurgood Marshall argued that the majority's decision severely limited the rights of disabled children and their parents to seek relief under Section 504 of the Rehabilitation Act when they face discrimination in public education. He contended that this ruling would force these families into a more complex and less effective legal process under Education of Handicapped Children Act (EHA), which was not designed to handle such cases. Furthermore, he criticized how this interpretation could potentially allow states to evade federal anti-discrimination laws by simply complying with EHA’s minimum standards without truly ensuring equal opportunities for disabled students.