Muller v. Commission on Special Education of East Islip Union Free School District

Treena Muller was a teenager with emotional and behavioral problems. Treena was born in Thailand and brought to the United States as an adoptee at the age of four, at which point she could not speak. Treena struggled with a speech impairment and with school beginning in kindergarten, and by the time she began high school she was failing courses, skipping school, and exhibiting other behavioral problems. Treena attempted suicide and was admitted to a private psychiatric treatment facility, where she was treated for a conduct disorder and depression. Treena was eventually discharged and began attending a private residential school for children with serious psychological problems, where she responded well and made progress emotionally and academically. Treena’s parents, the Mullers (plaintiffs) requested that the Islip Union Free School District (the district) pay for Treena’s attendance at the private school. After testing and hearings, the district determined that Treena was not eligible to be considered disabled and therefore not entitled to special-education services. The Mullers began an administrative appeal of the district’s decision, but the state ultimately upheld the denial of special education. The Mullers then filed a complaint in federal district court, alleging that the district’s actions violated the Individuals with Disabilities Education Act (IDEA). The district court held for the Mullers, ordered the district to qualify Treena as emotionally disabled, and awarded compensatory damages and attorneys’ fees to the family. The district appealed.