Alamo Heights Independent School District v. State Board of Education

Steven G. (plaintiff) lived with his mother, Beverly G. (plaintiff), in the Alamo Heights Independent School District (district) (defendant). Steven had a condition called cerebral dysplasia, which caused abnormal brain development and physical deformities of Steven’s face and hands. Steven was also diagnosed with severe mental disabilities, resulting in frequent tantrums and an inability to communicate through words or noises. Instead, Steven communicated by pointing at pictures and symbols on a communication board. From ages three to seven, Steven was in educational programs during every month of the year. After being enrolled in the district for first grade, Beverly requested that the district provide summer services for Steven to continue his education. The district previously offered summer programs for special education students but had recently changed the full-time summer program into a half-day, one-month program without transportation. Steven stayed with a babysitter during that summer and suffered regression in his ability to stand, point, and feed himself. After the second-grade school year, Beverly requested summer services from the district again but was denied. The only caretaker available during this summer was a mile outside the district boundary, and the district refused to provide out-of-district transportation even during the school year. Beverly appealed the denial of services to the Texas Education Agency, which ordered the district to provide full summer services and transportation for Steven. During the hearing process over the summer, Steven was enrolled in a childcare center with adaptive equipment and specialized staff, and Steven made progress in his social and feeding skills. However, Steven regressed in his motor skills due to a lack of structured physical training. The district filed suit in federal district court. During the trial process and the following summer, Steven was placed in a rehabilitation hospital with a full educational program involving physical, speech, and occupational therapy. Steven developed the ability to walk short distances in a walker and showed a marked improvement in his communication skills. At trial, the district court found that the district’s denial of summer services and transportation violated the Individuals with Disabilities Education Act (IDEA), formerly known as the Education for All Handicapped Children Act. The district appealed to the Fifth Circuit.