Parent/Professional Advocacy League v. City of Springfield, Massachusetts

The City of Springfield (city) (defendant) operated the state’s largest public school system, including the Springfield Public Day Schools (SPDS), an alternative set of schools for students with social-emotional behavioral disabilities. A student was enrolled in SPDS if his individualized education program (IEP) required placement in the alternative system. Other disabled students whose IEPs did not require placement with SPDS were enrolled in the traditional school system. SS (plaintiff) was a student in SPDS who filed a complaint with the Massachusetts Board of Special Education Appeals, asserting that his IEP violated the Individuals with Disabilities Education Act (IDEA) by denying him a free, appropriate public education in the least restrictive environment. The complaint further asserted class-wide disability-discrimination claims for a class of all students with mental disabilities placed in SPDS (plaintiffs). The hearing officer dismissed the complaint, and SS filed a class-action lawsuit in federal court. SS claimed that the city violated the Americans with Disabilities Act (ADA) by providing unequal educational services at SPDS and by denying students the opportunity to be educated in the most integrated setting appropriate for their needs. The city moved to dismiss. The district court denied the city’s motion but also denied SS’s class certification, finding that although SS had met the IDEA’s exhaustion requirement, the remainder of the class had not. Additionally, the class did not meet the requirements of Federal Rule of Civil Procedure 23(a). The students appealed the certification decision to the First Circuit.