Hall v. Vance County Board of Education

James Hall was a boy with above-average intelligence and dyslexia. James had struggled with schoolwork from a young age, and testing in second grade showed that he was significantly behind his peers in reading. Despite a recommendation from the school’s psychologist that James receive further evaluation, special help, and part-time placement in a learning-disability class, the Vance County Board of Education (the district) (defendant) and the school failed to take any such action. James failed second grade and continued to struggle academically. The school eventually created an individualized educational program (IEP) for James, which consisted only of placing him in a learning-disabilities classroom for a few hours a week. James showed little academic progress over the next few years. By fifth grade, testing showed that James was functionally illiterate, with reading-comprehension skills so low as to be untestable. James’s parents, the Halls (plaintiffs) enrolled James in a private school, where he quickly made substantial progress. The Halls sought reimbursement for James’s private-school tuition from the district. The district refused and proposed that James be placed back in the public school with a modified IEP. An administrative review of the matter by state officials held that placement in the public school was appropriate but that the district’s proposed IEP was inadequate. The Halls then sued the district in federal court. The court held that the district had failed to provide James with a free appropriate public education (FAPE) in past years, could not provide a FAPE to James during the coming school year, and must pay the costs for James’s private schooling. The district appealed.