Linda W. v. Indiana Department of Education

Ryan was a student with dyslexia in the state of Indiana. Ryan’s divorced parents, Linda W. (mother) and Steven V.D. (father) (plaintiffs), had joint custody of Ryan. Ryan lived with his mother 75 percent of the time within the boundaries of the South Bend School Corporation and with his father the other 25 percent of the time within the boundaries of the Mishawaka School City. Ryan’s mother and father felt that the individualized education program (IEP) provided to Ryan in Mishawaka was legally inadequate under the Individuals with Disabilities Education Act (IDEA). After multiple administrative hearings and appeals to the Indiana Department of Education (department) (defendant), Ryan’s mother and father filed suit in federal district court against the Mishawaka School Board (board) (defendant). The department moved for the court to either dismiss the suit for lack of subject-matter jurisdiction or to grant summary judgment in its favor. The department and the board argued that under Indiana state law, Ryan’s legal settlement was in South Bend and that the board did not owe a duty to provide for Ryan’s education and could not be sued under the IDEA. The district court found that because the lawsuit was brought under the authority of the IDEA and resulted from an administrative appeal process, the court had subject-matter jurisdiction. The court then addressed the department’s summary-judgment motion.