Justia Public Benefits Opinion Summaries

Plaintiffs placed their son in a specialized private school designed to educate children with learning disabilities and filed suit against the District for tuition reimbursement under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. An Impartial Hearing Officer (IHO) awarded tuition reimbursement but the State Review Officer (SRO) reversed. The court held that the SRO's decision was insufficiently reasoned to merit deference and deferred to the IHO's decision, which was more thorough and carefully considered. The court affirmed the dismissal of plaintiff's claim under Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, where the parents had not presented sufficient evidence of bad faith or gross misjudgment. View "C.L. v. Scarsdale Union Free Sch. Dist." on Justia Law

E attended kindergarten and first grade in the Ridley School District, 2006-2008, receiving special services for learning disabilities and health problems. After first grade, her parents concluded that the school was not meeting E’s needs, and enrolled her at a private school, Benchmark, that specializes in educating students with learning disabilities, then filed a complaint with the Pennsylvania Department of Education claiming violation of the Individuals with Disabilities Education Act, 20 U.S.C. 1415(j), and the Rehabilitation Act, 29 U.S.C. 794(b)(2), by failing to provide a suitable Individualized Education Program. A hearing officer found no violations during kindergarten year, but awarded compensatory education for first grade and ordered Ridley to reimburse tuition and transportation costs for 2008-2009. Two years later, a federal district court reversed, finding the proposed IEP adequate. The Third Circuit affirmed. Meanwhile, the parents sought payment for Benchmark costs from the date of the hearing officer’s decision forward pursuant to the IDEA, which states that a disabled child shall remain in the child’s current educational setting pending resolution of a dispute over the child‘s placement. The district court ruled in favor of the parents, rejecting the district’s timeliness contentions and awarded costs for three years, $57,658.38. The Third Circuit affirmed. It is impossible to protect a child‘s educational status quo without sometimes taxing school districts for private education costs that ultimately will be deemed unnecessary. View "M. R. v. Ridley Sch. Dist." on Justia Law

Plaintiffs, on behalf of their daughter, filed suit challenging the district's implementation of a new individualized education program (IEP) for their daughter under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Determining that the daughter's case was not moot, the court concluded that the court need not decide whether the various notice requirements were satisfied because whatever notice deficiencies there could have been in this case, they did not warrant relief; there was no error in requiring the parents to present a complaint and demand a due process hearing because they disagreed with the IEP team's decision; the district court correctly stated the Loren F. ex. rel. Fisher v. Atlanta Independent School System standard, fully reviewed the administrative record, and independently analyzed each of the parents' claims; the district court did not abuse its discretion when it issued the parents' proposed order and then decided the case on summary judgment; and the court held that 42 U.S.C. 1983 actions for denial of rights conferred by the IDEA were barred because the IDEA's comprehensive enforcement scheme provided the sole remedy for statutory violations and, therefore, the district court did not err in dismissing the parents' section 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "K.A. v. Fulton County Sch. Dist." on Justia Law

Under the Individuals with Disabilities Education Act (IDEA), states that provide special education funds are eligible for federal funds to implement state-wide special education programs that guarantee a free appropriate public education (FAPE) to eligible disabled children, 20 U.S.C. 1412(a)(1)(A). Pennsylvania enacted 24 P.S. 25-2509.5, its special education funding formula, under which each school district receives a base supplement, calculated by apportioning the total amount of base supplement money available among all districts based on the average daily membership of the district from the prior year under the assumption that 16% of students in each district are disabled. Plaintiffs, disabled students who attend schools in districts with a 17% or greater enrollment of special needs students and with a market value/personal income ratio of .65 or greater, claimed that Pennsylvania’s method violates IDEA, the Americans with Disabilities Act, and the Rehabilitation Act The district court found that the formula did not deprive the class of a FAPE as required by the IDEA and did not discriminate in violation of either the ADA or RA. The Third Circuit affirmed, noting that there was no evidence that any class member was deprived of a service available to nonclass members. View "CG v. PA Dep't of Educ." on Justia Law

Plaintiff, a severely disabled student, filed suit arguing that he was entitled to remain at a private school he had been attending since the age of seven. The Department issued a formal notice that plaintiff's special education placement at the school would end when he turned 20 years old. Plaintiff argued that he was entitled to remain at the school until he was 22 years old. At issue on appeal was whether the "stay put" provision in the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415j, applied to a student who has exceeded a state-imposed age limit on eligibility for public education. The court affirmed the judgment of the district court, concluding that the district court correctly granted plaintiff's motion for stay put. Plaintiff was entitled to remain at the school as his stay-put placement from the date he filed his administrative complaint and he was entitled to remain there until his case was finally resolved. View "A.D. v. State of Hawaii Dep't of Educ." on Justia Law

Plaintiffs filed a due-process complaint against the DOE seeking tuition reimbursement after plaintiffs enrolled their autistic child in a private school because the DOE failed to provide the child with a free and appropriate public education under the Individuals with Disabilities Education Improvement Act (IDEA), 20 U.S.C. 1400 et seq. The court affirmed the state review officer's determination that the hearing record did not support the impartial hearing officer's determination that the lack of a functional behavior assessment (FBA) rose to the level of denying the child a free and appropriate public education (FAPE) where the individualized education program (IEP) addressed behavioral needs. Further, the IEP's failure to include parental counseling did not deny the child a FAPE; the SRO did not rely upon impermissible retrospection and the court deferred to her analysis; and the court found plaintiffs' remaining arguments to be without merit. Accordingly, the court affirmed the grant of summary judgment in favor of defendants. View "M.W. v. New York City Dep't of Educ." on Justia Law

Munir sent his son, O.M., to a private residential facility and a private boarding school after multiple suicide attempts, and sought reimbursement for the cost of the placements from the school district under the Individuals with Disabilities Education Act (IDEA), which requires that states receiving federal education funding ensure that disabled children receive a free appropriate public education, 20 U.S.C. 1412(a)(1) or pay for their education elsewhere if a child require specialized services that the public institution cannot provide. The district court denied the request, reasoning that O.M. had emotional problems, but that those problems were not affecting his ability to learn. The Third Circuit affirmed, finding that O.M.’s placement was to meet his mental health needs; any educational benefit he received from the placement was incidental. O.M. was an above-average student, without serious attendance problems, and socialized well in the district school. An individualized education plan offered by the district satisfied its IDEA obligations. View "Munir v. Pottsville Area Sch. Dist." on Justia Law

ITT is a for-profit institution with more than 140 locations and offers post-secondary education. Leveski, who worked at the ITT campus, alleged, under the qui tam provisions of the False Claims Act, 31 U.S.C. 3730(b) that ITT knowingly submitted false claims to the Department of Education to receive funds from federal student financial assistance programs under the Higher Education Act, 20 U.S.C. 1001. The district court dismissed for lack of jurisdiction, finding that the allegations had already been publicly disclosed and that Leveski was not the original source of the allegations. The court granted sanctions of $394,998.33 against Leveski's lawyers. The Seventh Circuit reversed, finding the allegations that ITT paid illegal incentive compensation throughout Leveski’s employment as a recruiter and financial aid assistant, sufficiently distinct from prior public disclosures to give the court jurisdiction. The court noted the lack of temporal overlap with allegations by other ITT employees and Leveski’s more detailed allegations. View "Timothy J. Matusheski v. ITT Educational Services, Inc" on Justia Law

This case began as a dispute over the results of CM's special education evaluation under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. At issue on appeal was: (1) the ALJ's dismissal of several of CM's claims against Lafayette prior to holding a due process hearing; and (2) the district court's dismissal of MM's, CM's parents, separate claims against the California Department of Education (CDE). The court held that the district court correctly dismissed MM's claims against Lafayette challenging the ALJ's statute of limitations ruling as being premature. The district court did not abuse its discretion in dismissing the fourth claim as duplicative and correctly held that the CDE had no authority to oversee the individual decisions of OAH's hearing officers. Accordingly, the court affirmed the judgment of the district court. View "M. M., et al. v. Lafayette Sch. Dist., et al." on Justia Law

Plaintiff brought this qui tam suit alleging that the District of Columbia and its schools violated the False Claims Act (FCA), 31 U.S.C. 3729-3733, by submitting a Medicaid reimbursement claim without maintaining adequate supporting documents. The district court dismissed the case, relying on the court's precedent in United States ex rel. Findley v. FPC-Boron Employees' Club. Because the court concluded that the Supreme Court had implicitly overruled Findley in Rockwell International Corp. v. United States, the court reversed. View "Davis v. DC" on Justia Law