Marie O. v. Edgar

No. 94 C 1471, 1996 U.S. Dist. LEXIS 1070 (1996)

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Marie O. v. Edgar

United States District Court for the Northern District of Illinois
No. 94 C 1471, 1996 U.S. Dist. LEXIS 1070 (1996)

  • Written by Alexander Hager-DeMyer, JD

Facts

Part H was a federal program created under the Individuals with Disabilities Education Act (IDEA) that incentivized states to develop and implement a statewide system to provide early-intervention services to developmentally delayed infants and toddlers. Part H laid out extensive and specific requirements for participation, including particular demographics that needed to be served in particular ways and a list of systems that needed to be implemented. Federal funding was conditioned each year on compliance with Part H requirements. The law also explicitly stated that after five years, a state had to have, at a minimum, certain programs established to serve all eligible children. The State of Illinois (state) (defendant) opted into the Part H program and began receiving federal funding. However, due to funding difficulties and a lack of qualified personnel, the state fell significantly behind on its requirements. The state continued to receive funds past its fifth year of participation in the program. After eight years in the program, the state did not have the required systems in place and had roughly 26,000 eligible children who were not receiving the early-intervention services guaranteed under Part H. A lawsuit was filed on behalf of a class of developmentally delayed infants and toddlers (children) (plaintiffs), and the children filed for summary judgment, alleging a violation of the IDEA.

Rule of Law

Issue

Holding and Reasoning (Kocoras, J.)

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