Manecke v. School Board of Pinellas County, Florida

Lauren Manecke (plaintiff) was a high school student who was epileptic and had several other physical and emotional disabilities. Manecke started high school in traditional programs supplemented by special-education classes. Manecke engaged in a sexual relationship with a 32-year-old man and ran away with him for six days. After the incident, Manecke’s mother withdrew Manecke from school and requested the local school board (board) (defendant) to place Manecke at a special-education school. The board created an individual education program (IEP) for Manecke and placed her at the Nina Harris School for exceptional children. Manecke adjusted well to school but fought incessantly with her family at home. As a result, Manecke’s mother contacted the board and requested a due-process hearing regarding Manecke’s placement, hoping to have the board place Manecke in an out-of-state residential facility. The board sent the request to its attorney, who did not initiate any proceedings. Manecke’s family met with the board in an informal mediation but did not reach a compromise. The Maneckes were contacted by an out-of-state residential school with an opening for Manecke, and Manecke’s family enrolled her in the new facility. After complaining to the United States Office of Civil Rights, the Maneckes filed suit against the board in federal district court under the Rehabilitation Act and 42 U.S.C. § 1983. The Maneckes argued that because they were denied a due-process hearing, they were forced to personally transfer Manecke to the residential school and needed reimbursement for the costs. The board argued that the claims fell under the Education for All Handicapped Children Act (EHA), which did not allow for monetary recovery. The district court dismissed both claims, and the Maneckes appealed. The court of appeals affirmed the dismissal of the Rehabilitation Act claim and addressed the § 1983 claim.