Irving Independent School District v. Tatro

Amber Tatro (plaintiff) was a student in the Irving Independent School District (district) (defendant) who was born with spina bifida. Tatro’s condition prevented Tatro from emptying her bladder voluntarily and required her to have a catheter inserted into her urethra every few hours through a procedure called clean intermittent catheterization (CIC). CIC was a simple procedure that could be performed in a few minutes by a layperson with less than an hour of training. Tatro was considered disabled under the Individuals with Disabilities Education Act (IDEA), formerly known as the Education of the Handicapped Act, and Tatro’s parents worked with the district to create an individualized education program (IEP) for Tatro. The IEP placed Tatro in early-childhood-development classes with special services such as physical and occupational therapies. However, the IEP did not provide for school personnel to administer CIC. After exhausting administrative avenues, Tatro’s family filed suit in federal district court, arguing that the district violated the IDEA by refusing to provide CIC. The district court found that CIC was not a service the district had to provide. Tatro appealed the ruling, and the appellate court reversed, finding that CIC was a related service that the district had to provide under the IDEA. The appellate court remanded the case, and the district court ordered the district to provide CIC during school hours. The district appealed, and the appellate court affirmed the order. The district appealed to the United States Supreme Court.