DL by Landon v. St. Louis City School District

DL (plaintiff) was a student in the St. Louis City School District (district) (defendant) with medically diagnosed autism. DL exhibited severe behavioral issues like toileting difficulties, hitting, and suicidal threats. Until fourth grade, DL received specialized education, and his individualized education program (IEP) emphasized the importance of occupational therapy (OT) and sensory support. During DL’s fourth-grade year, the IEP team met to determine a new placement. Against recommendations from DL’s psychiatrist and contrary to DL’s IEP history, the team removed OT from DL’s IEP and placed DL at Educational Therapeutic Support at Madison (Madison), a school for children with behavioral issues. However, Madison had no autistic students, autism-specific resources, or staff with experience working with autistic children. Instead, DL’s parents placed DL at Giant Steps, a private school with better resources and experienced staff, and DL showed progress. DL filed a due-process complaint claiming that the district violated the Individuals with Disabilities Education Act (IDEA) by placing him at an inappropriate school and denying him a free appropriate public education. DL sought tuition reimbursement for Giant Steps. Before the hearing, Madison built a sensory room and enrolled three autistic students. DL’s parents were not informed of Madison’s improvements or of any risk of limited tuition reimbursement if DL stayed at Giant Steps. The hearing commission ruled that Madison was now an appropriate placement and denied tuition reimbursement. DL appealed to a district court. The district court found that Madison was not initially an appropriate placement and granted tuition reimbursement limited to the time prior to Madison’s improvements. DL appealed to the Eighth Circuit.