Forest Grove School District v. TA

557 U.S. 230 (2009)

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Forest Grove School District v. TA

United States Supreme Court
557 U.S. 230 (2009)

  • Written by Alexander Hager-DeMyer, JD

Facts

TA (plaintiff) was a student in the Forest Grove School District (district) (defendant). From kindergarten through eighth grade, TA struggled to pay attention in class and complete his assignments. During TA’s first year of high school, the district performed a superficial evaluation of TA and concluded that he did not qualify for special-education services or require additional testing for learning disabilities, including attention deficit hyperactivity disorder (ADHD). After TA’s first two difficult years in high school, TA was diagnosed with ADHD and other learning disabilities by a private specialist. On professional advice, TA’s parents enrolled TA in a specialized private school. TA requested an administrative due-process hearing to discuss TA’s eligibility for special-education services. The district performed another evaluation and determined that TA’s conditions were not severe enough to qualify for special education. After hearing testimony, the hearing officer disagreed and found that the district failed to properly identify TA as a special-education student and failed to provide TA with a free appropriate public education under the Individuals with Disabilities Education Act (IDEA). The hearing officer ordered the district to provide tuition reimbursement for TA’s private schooling. The district appealed to a federal district court, which reversed the ruling. The court found that amendments to the IDEA denied reimbursement to students who had not previously received special-education services from a public agency. TA appealed to the Ninth Circuit, which reversed the decision. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Dissent (Souter, J.)

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