Draper v. Atlanta Independent School System

Jarron Draper (plaintiff) was a student with learning disabilities in the Atlanta Independent School System (system) (defendant). Despite clear difficulties in class, Draper was not evaluated by the system until four years into his schooling. The initial evaluation misdiagnosed Draper with an intellectual disability and failed to assess him for learning disabilities. Draper was subsequently placed in a specialized class for children with mild intellectual disabilities. Draper was not reevaluated for five years, in violation of the Individuals with Disabilities Education Act (IDEA). Upon reevaluation, Draper was diagnosed with learning disabilities and had his education program adjusted. However, the system’s program changes produced no results over two years. Draper requested an administrative hearing for alleged IDEA violations. The administrative-law judge (ALJ) found that the system had violated the IDEA and offered Draper a compensatory-education award and a choice between a public-school placement with additional services or a basic, tuition-capped private-school placement. Draper took the private option while the system appealed the decision in district court. The district court affirmed the ALJ’s findings and awarded Draper the private-school placement, removing tuition limits and adding full special-education services to assist in making up lost ground. The system appealed to the Eleventh Circuit.