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Metropolitan School District v. Davila

United States Court of Appeals for the Seventh Circuit
969 F.2d 485 (1992)


Facts

Robert Davila (defendant), the Secretary of the Department of Education, wrote a letter interpreting Part B of the Individuals with Disabilities Education Act (IDEA). The position set forth in the letter was issued without public comment and was not published in the Federal Register or the Code of Federal Regulations. The Metropolitan School District of Wayne Township (School District) (plaintiff) sued Davila and the Department of Education (defendant) on behalf of itself and similarly situated providers of educational services, arguing that the position expressed in the letter placed a large financial burden on school districts and that they were entitled to notice of the proposed rule and an opportunity to comment. Upon finding that the letter was a legislative ruling subject to the notice and comment requirements of the Administrative Procedure Act (APA), the district court granted summary judgment for the School District.

Rule of Law

Issue

Holding and Reasoning (Bauer, J.)

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