Metropolitan Government v. Cook

Curtis Cook (plaintiff) was a disabled student in the school system operated by the Metropolitan Government of Nashville and Davidson County (government) (defendant). Cook exhibited behavioral issues, and the government’s special-education personnel met with Cook’s parents to discuss Cook’s educational placement as required by the Individuals with Disabilities Education Act (IDEA), formerly known as the Education for All Handicapped Children Act. Cook’s parents argued that Cook should be placed in the Brehm School, a specialized institution, but the government contended that Cook’s needs could be met locally in the public school where he was currently enrolled. The Cooks requested an administrative hearing regarding the placement. The administrative-law judge (ALJ) found that Cook required intensive reading and language therapy and that the Brehm School placement requested by Cook’s parents would provide the necessary services. The ALJ heard no testimony regarding other, less restrictive placement options that would permit Cook to be better mainstreamed with his nondisabled peers. The government appealed to a district court to reverse the ALJ’s decision to place Cook at the Brehm School, arguing that the placement violated the IDEA’s requirement that Cook be educated in the least restrictive environment possible, one that permitted the most appropriate contact with nondisabled children. The district court heard testimony regarding alternative placement options in the public-school system and found in favor of the government, reversing the ALJ’s decision. Cook’s parents appealed to the Sixth Circuit, arguing that the district court improperly heard testimony about alternate placements that was not provided at the administrative hearing.