Eschenasy v. New York City Department of Education

Ann Eschenasy was a disturbed teenager who had continually struggled with behavior and school problems from a young age. Over the years, Ann had stolen, lied, used drugs, run away from home, attempted suicide, cut herself, and pulled out her hair. She had been enrolled in, and suspended and expelled from, a number of private schools and showed poor academic progress overall. Ann had received multiple efforts at treatment in a variety of settings and had been diagnosed with various conditions, including conduct disorders, borderline-personality disorders, and mood disorders. After repeated failures at schools focused on children with emotional problems, Ann’s parents, the Eschensays (plaintiffs) eventually enrolled her in a restrictive and structured residential school, where she made academic and emotional progress. The Eschensays petitioned the New York City Department of Education (the district) (defendant) to pay for Ann’s tuition at the school under the Individuals with Disabilities Education Act (IDEA), but the district held that Ann was not disabled and therefore ineligible for special-education benefits. The state ultimately upheld the district’s decision after the Eschensays petitioned for an administrative review. The Eschensays brought their claim for Ann’s coverage under the IDEA to federal district court.