Neosho R-V School District v. Clark

Robert Clark (plaintiff) was a student with disabilities in the Neosho R-V School District (district) (defendant). Because of his conditions, Clark exhibited inappropriate behavior and struggled to interact appropriately with his classmates and teachers. Clark’s parents initiated due-process proceedings against the district because of Clark’s difficulties in school, and a settlement agreement provided that the district would pay for a full-time paraprofessional for Clark and develop well-researched, specific behavioral interventions and strategies to manage Clark’s behavior. The district developed an individualized education program (IEP) for Clark, but the IEP’s behavior plan consisted only of goals and objectives for Clark’s behavior rather than the required specific strategies and interventions. Clark’s teachers and paraprofessionals struggled to manage his behavior, which kept Clark from being mainstreamed with his nondisabled peers as his parents and IEP intended. Clark’s academic progress was also significantly undermined by his behavioral issues going unmanaged. Clark’s parents initiated another due-process hearing, alleging that the district’s IEP was inadequate under the Individuals with Disabilities Education Act (IDEA). The administrative panel found that the IEP’s behavioral plan was inadequate for Clark’s needs and that Clark was unable to gain an educational benefit as required by the IDEA. The district sought judicial review of the decision in federal district court. The court affirmed the decision and awarded Clark attorney’s fees, but the court denied Clark’s request for expert-witness fees. Both parties appealed to the Eighth Circuit.