Florence County School District Four v. Carter

In 1985, Shannon Carter (plaintiff) was diagnosed with a learning disability during her ninth-grade year at a school in Florence County School District Four (the district) (defendant). The Individuals with Disabilities Education Act (IDEA) required school officials to meet with Shannon’s parents to develop an individualized education program (IEP) for Shannon. However, Shannon’s parents (the Carters) were dissatisfied with the district’s proposed IEP. The Carters initiated state administrative proceedings to challenge the IEP, but both the local educational officer and the state educational agency’s hearing officer upheld the school’s proposed IEP. Meanwhile, the Carters paid out of pocket for Shannon to attend Trident Academy (Trident), a private school that specialized in educating children with disabilities. Shannon graduated from Trident in 1988. After the unsuccessful administrative proceedings, the Carters sued the district in federal district court, alleging that the school district had violated the IDEA by failing to provide Shannon with a free, appropriate public education, and requesting reimbursement for Shannon’s tuition and costs at Trident. The school district argued that Trident was not a valid private-school placement because it did not meet South Carolina’s statewide educational standards. Notably, however, South Carolina approved private-school placements under the IDEA only on a case-by-case basis; the state did not maintain a list of preapproved schools. The district court found that the school district had proposed an inappropriate IEP and that Trident had provided Shannon with an excellent education that had substantially complied with the IDEA. The district court ordered the school district to reimburse the Carters. The school district appealed, and the United States Court of Appeals for the Fourth Circuit affirmed. The United States Supreme Court then granted the school district’s petition for a writ of certiorari to consider the narrow issue of whether Shannon’s parents could be reimbursed for private-school costs if the private school did not meet the technical requirements of the IDEA but had otherwise provided Shannon with an appropriate education under the IDEA.