Murray v. Montrose County School District

Tyler Murray (plaintiff) was a student in the Montrose County School District (defendant). Tyler had cerebral palsy, which led to significant mental and physical impairments and speech difficulties. The Murrays lived a few blocks from Olathe Elementary School (Olathe), a school that offered basic services to disabled students with mild to moderate needs. Olathe was not fully accessible to students with disabilities like Tyler’s. Before Tyler started kindergarten, a staffing team at Olathe met to create an individualized education program (IEP) for Tyler in accordance with the Individuals with Disabilities Education Act (IDEA). The staffing team determined that Tyler’s IEP could be implemented at Olathe, and Tyler enrolled there for school. Over the next few years, Tyler and his IEP were reevaluated several times as required by IDEA, and after several modifications, the staff at Olathe grew concerned that Tyler was not sufficiently progressing in his current education placement. District personnel met with the Murrays and suggested moving Tyler to Northside Elementary School (Northside), a school located in another town in the district that had specific programming to support disabled students with severe or profound needs. The Murrays objected and demanded that Tyler remain with his sibling and neighborhood friends at Olathe. After additional evaluations and continuing disagreements between district personnel and the Murrays over Tyler’s placement, a due-process hearing was held. It was determined that Tyler needed to transfer to Northside, and the Murrays appealed the decision in federal district court. The district court affirmed the administrative decision, and the Murrays appealed to the Tenth Circuit, arguing that IDEA requirements had a presumption of neighborhood schooling for disabled students that meant Tyler should remain at Olathe rather than transfer to Northside.