Independent School District No. 12 v. Minnesota Department of Education

A child (student) (plaintiff) with autism was a resident of Independent School District No. 12, Centennial (district) (defendant). The student was considered disabled under the Individuals with Disabilities Education Act (IDEA), and the district worked with the student’s parents to create an individualized education program (IEP), as required by law. The student’s parents contacted the IEP team to discuss supplementary aids and services they believed would be necessary for the student to participate in extracurricular and nonacademic activities like volleyball, after-school clubs, and a class graduation party. The district refused to call an IEP meeting to discuss the extracurricular aids and services. The student’s parents filed an IDEA complaint with the Minnesota Department of Education (department) (plaintiff). The department found that the district violated the IDEA by failing to discuss the student’s participation in nonacademic activities, and the district was ordered to meet and determine what aids and services would be necessary for the student to participate. The district appealed the decision to a Minnesota appellate court. The appellate court found that the district was obligated to consider, through an IEP team, whether extracurricular activies should be included in a student’s IEP and, if so, what aids and services would be required to allow the student’s participation. However, the court determined that an IEP needed to include only the extracurricular activities that were appropriate and required for the student’s education. The student and the department appealed the decision to the Minnesota Supreme Court.