Kings Local School District v. Zelazny

Ariel Zelazny (defendant) was a student at Kings High School (Kings). Zelazny had obsessive compulsive disorder, Tourette syndrome, and Asperger’s syndrome, which qualified him for special-education services under the Individuals with Disabilities Education Act (IDEA). Kings implemented an individualized education program (IEP) for Zelazny during his seventh-grade year and renewed it during his eighth-grade year. Zelazny performed well academically during his progression from school year to school year. Shortly after a similar version of his IEP was finalized for Zelazny’s ninth-grade year, Zelazny’s parents began to feel that Zelazny was having trouble in school behaviorally and socially. Zelazny’s parents requested an emergency meeting to revise Zelazny’s IEP and hired a consultant who submitted a report of recommendations to Kings. Kings held three meetings and implemented a revised IEP that incorporated some but not all of the consultant’s recommendations. Zelazny’s parents were unsatisfied with the revisions and arranged for Zelazny to enter a private school the following fall. Meanwhile, Zelazny continued to perform well at Kings academically and was on track to advance to the next grade. Zelazny’s parents requested a due-process hearing at which they claimed that Kings had failed to provide Zelazny with a free appropriate public education. The hearing officer agreed with Zelazny’s parents and ordered the school district (district) (plaintiff) to pay the cost of Zelazny’s private schooling. After failing to prevail at an administrative appeal, the district brought an action in district court to review the hearing officer’s decision. The district court overturned the decision, and Zelazny’s parents appealed.