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In 1890, their father informed the Board of Education that he wanted his daughters to attend the school nearest their home. He argued the Second Ward School had room for additional children. Since the Independence Board had established separate classes for African American children within one of their four primary schools, the superintendent refused to enroll Bertha and Lilly in the school near their home. Knox sought legal help to compel the Board to honor his request. -
Brown v. Board of Education of Topeka, 347 U.S. 483, was a landmark decision of the U.S. Supreme Court in which the Court ruled that U.S. state laws establishing racial segregation in public schools are unconstitutional, even if the segregated schools are otherwise equal in quality. -
This was the first special education case decided by the Supreme Court. In this case, the Court held that an IEP must be reasonably calculated for a child to receive educational benefit, but the school district is not required to provide every service necessary to maximize a child’s potential. -
The Court held that provision of clean intermittent catheterization was a “related service” under the IDEA and not a “medical service,” because the service was necessary for the student to attend school. The services requested did not fall within the medical exclusion because they need not be performed by a physician. The Court noted that “Congress sought primarily to make public education available to handicapped children and to make such access meaningful.” -
The Court established, for the first time, the right of parents to be reimbursed for their expenditures for private special education. -
The Court addressed the IDEA’s “stay put” provision, explaining that in enacting “stay put”, Congress intended “to strip schools of the unilateral authority they had traditionally employed to exclude disabled students … from school.” -
The Third Circuit held that compensatory education is available to respond to situations where a school district flagrantly fails to comply with the requirements of IDEA. -
Children with disabilities are entitled to be educated in the Least Restrictive Environment (LRE) that is appropriate to meet their needs. In this case, the Court adopted a two part test to determine whether a child has been placed in the least restrictive environment. It must first be determined whether education in the regular classroom, with the use of supplementary aids and services, can be achieved satisfactorily. -
The Third Circuit has held that the educational benefit to which each student is entitled must be more than “trivial,” it must be “meaningful.” The Third Circuit inferred that Congress must have envisioned that “significant learning” would occur. -
In this case, the Third Circuit held that “the provision of merely “more than a trivial educational benefit” does not meet the [Polk] standard . . . . Rowley and Polk reject a bright-line rule on the amount of benefit required of an appropriate IEP in favor of an approach requiring a student-by-student analysis that carefully considers the student’s individual abilities. -
The Court ruled that in order to obtain attorney fees as a “prevailing party,” the party must secure either a judgment on the merits or a court-ordered consent decree. -
The Court held that, absent a state statute to the contrary, the party seeking relief bears the burden of proof in an administrative due process proceeding. -
The Court held that a provision of the IDEA authorizing “reasonable attorneys’ fees for prevailing parents does not authorize the recovery of fees for expert’s services. -
Here, the Court determined that parents may pursue claims under the Individuals with Disabilities Education Act (IDEA) on their own behalf, as the rights conferred to parents under the Act exist independently from the rights of their child. -
This case clarified how to interpret IDEA’s two-year statute of limitations. The Court held that the IDEA’s statute of limitations creates a “discovery rule” approach, in which the statute begins to run on the date the parents knew or should have known of the FAPE violation, rather than an “occurrence rule” approach, wherein the statute of limitations period would begin to run on the actual date of the violation.
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