Gary S. v. Manchester School District

374 F.3d 15 (2004)

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Gary S. v. Manchester School District

United States Court of Appeals for the First Circuit
374 F.3d 15 (2004)

  • Written by Alexander Hager-DeMyer, JD

Facts

Andrew S. was a disabled child who attended a private Catholic elementary school within the Manchester School District (school district) (defendant). Under the Individuals with Disabilities Education Act (IDEA), Andrew was entitled to fewer special-educational services than disabled students enrolled in public school. Andrew also was not entitled to the due-process hearing provided by the IDEA to public-school students. Andrew’s parents (plaintiffs) filed suit in federal district court, arguing that because disabled students in religious private schools were treated differently from the public-school students, the IDEA violated the Free Exercise Clause, the Due Process Clause, the Equal Protection Clause, and the Religious Freedom Restoration Act. The district court ruled in favor of the school district after analyzing the IDEA under a rational-basis test and finding that the law was constitutional on all grounds. The parents appealed to the First Circuit. The appellate court denied the due-process claim, finding that the school district did not condition governmental benefits on the relinquishment of fundamental rights. The court then addressed the other claims.

Rule of Law

Issue

Holding and Reasoning (Campbell, J.)

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