CJN v. Minneapolis Public Schools

CJN (plaintiff) was a disabled student in the Minneapolis Public Schools (district) (defendant) who suffered from brain lesions and psychiatric illnesses. CJN demonstrated significant behavioral difficulties but average academic progress. Under the Individuals with Disabilities Education Act (IDEA), CJN received an individualized education program (IEP). In third grade, CJN was placed in a special education program while waiting on behavioral evaluations. CJN was then transferred to another teacher’s program that had higher academic performance standards and increased structure. To meet CJN’s needs, the teacher offered reduced homework, positive reinforcement, and a reward system for good behavior. The district imposed suspension on CJN only for physical aggression. CJN behaved poorly, causing the teacher to use increasingly frequent restraints and time-outs in response. CJN’s IEP team met twice to discuss his evaluations and his behavioral issues. The team reviewed and rejected some suggestions from the evaluations and CJN’s mother but agreed to others. CJN was transferred to a new school, where he would receive individualized instruction and spend time at a treatment facility. Days later, an outburst sent CJN to a crisis center, and the IEP team agreed to homeschooling. However, CJN’s mother transferred CJN to a private school. CJN’s mother filed a complaint, seeking private-school reimbursement and declaratory judgment that the district failed to provide CJN a free, appropriate public education during the third grade. A hearing officer ruled in favor of CJN, and the district appealed to a state hearing review officer (HRO). The HRO reversed, and a district court upheld the HRO’s ruling, finding that the district had continually tailored CJN’s IEP to his behavioral needs and that CJN was showing average academic progress in compliance with the IDEA. CJN’s mother appealed to the Eighth Circuit, arguing that the district court’s decision improperly rested on academic progress alone and that the time-outs and restraints showed a lack of appropriate education.