Justia Public Benefits Opinion Summaries

Appellant, a former student in the Forest Grove School District ("Forest Grove"), appealed the district court's determination that he was not entitled to an award of reimbursement for his private school tuition under the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1415(i)(2)(C). At issue was whether the district court abused its discretion in holding that equitable considerations did not support any award of private-school tuition at Mount Bachelor Academy as a result of Forest Grove's failure to provide appellant with a Free and Appropriate Education ("FAPE") under the IDEA. The court held that the district court did not abuse its discretion in holding that there was sufficient evidence in the record to support the district court's factual determination where appellant's parents enrolled him at Mount Bachelor solely because of his drug abuse and behavioral problems.

The Equal Rights Center ("ERC") sued Post Properties, Inc. ("Post") alleging that Post designed, constructed, and operated its apartment complexes in a manner that violated the Fair Housing Act ("FHA"), as amended by the Fair Housing Amendments Act of 1988 ("FHAA"), 42 U.S.C. 3601-3631, and Title III of the Americans with Disabilities Act ("ADA"), 42 U.S.C. 12181-12189. At issue was whether the district court properly granted summary judgment to Post on the ground that the ERC lacked standing to bring suit where it failed to demonstrate an injury in fact. The court held that the ERC failed to demonstrate that its injury was actual or imminent at the time of the filed suit and held that the district court erroneously concluded that the ERC could not establish standing because it chose to redirect its resources to investigate Post's allegedly discriminatory practice. Therefore, the court focused on whether the organizational plaintiff undertook expenditures in response to, and to counteract, the effects of a defendant's alleged discrimination rather than in anticipation of litigation and determined that the ERC failed to demonstrate that it suffered an injury in fact that was actual or imminent at the time it filed the suit.

Appellants, a child with a learning disability and his parents, sued the Special School District No. 1 ("School District") in Minneapolis, Minnesota alleging that the School District violated his rights under the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1400, by denying him a free appropriate public education. At issue was whether the district court properly granted summary judgment in favor of the School District when it determined that the parents were not entitled to reimbursement from the School District for one year of private tuition when they transferred the child to a private education institution ("institution"). The court reversed the district court's decision and held that appellants were not precluded from reimbursement for tuition for the 2008-2009 academic year where the institution was a proper placement for the child and where the institution did not need to satisfy the least-restrictive environment requirement to be "proper" under the IDEA.