C.N. v. Willmar Public Schools, Independent School District No. 347
United States Court of Appeals for the Eighth Circuit
591 F.3d 624 (2010)
C.N. (plaintiff), who had a communications disorder and attentional and hyperactivity problems, was enrolled in Willmar Public Schools, Independent School District No. 347 (Willmar) (defendant). Under the Individuals with Disabilities Education Act (act), school districts were required to develop an individualized education program (IEP) for each disabled student. Willmar created an IEP for C.N. that authorized the use of restraint holds and seclusion if C.N. exhibited certain target behaviors. C.N.’s special-education teacher allegedly used the restraint and seclusion techniques improperly. C.N.’s mother withdrew C.N. from Willmar and enrolled C.N. in a different school district. Subsequently, C.N., through her mother, requested a due-process hearing, challenging the adequacy of the educational services that Willmar had provided. The administrative-law judge granted Willmar’s motion to dismiss the hearing request for lack of jurisdiction because C.N. was no longer enrolled in Willmar and had transferred to another district without first requesting a hearing against Willmar. C.N. appealed the ruling to the federal district court and asserted a claim against Willmar under the act. The district court dismissed C.N.’s claim because C.N. had not requested a due-process hearing on her claim against Willmar until after leaving Willmar. C.N. appealed.
Rule of Law
Holding and Reasoning (Beam, J.)
Concurrence (Colloton, J.)
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