Mrs. W. v. Tirozzi
United States Court of Appeals for the Second Circuit
832 F.2d 748 (1987)

- Written by Carolyn Strutton, JD
Facts
Mrs. W, Mrs. B., and Connecticut Legal Services (the advocates) (plaintiffs) brought a civil-rights action against the Connecticut State Board of Education and various state officials (the state board) (defendants) under 42 U.S.C. § 1983, alleging that the state had violated the Education for All Handicapped Children Act (EHA), other federal statutes, and constitutional protections. The advocates’ complaint requested an injunction requiring the state to formulate and implement complaint-resolution procedures for disputes related to the education of their disabled children. The state board moved for a judgment on the pleadings. The district court granted the state board’s motion, ruling that advocates had no private right of action under § 1983 because the EHA was a comprehensive remedial statute. The advocates appealed.
Rule of Law
Issue
Holding and Reasoning (Cardamone, J.)
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