Polk v. Central Susquehanna Intermediate Unit 16

Christopher Polk was a severely mentally and developmentally disabled teenager with the mental capacity of a toddler. Christopher received personalized special-education services through his local school district and a multi-county educational administrative agency (the school) (defendants). Christopher had a full-time classroom aid, and the goal of Christopher’s educational program was to obtain basic life skills, such as feeding himself, personal care, and sitting and standing independently. Although the school had previously provided Christopher with direct care from a licensed physical therapist, it had since switched to a new model under which a physical therapist came in once a month to instruct the classroom teacher on ways to integrate physical therapy into Christopher’s education. Christopher’s parents, the Polks (plaintiff) challenged this decision with state officials, claiming that Christopher required direct treatment by a physical therapist. The state denied the Polks’ claim and held that the education Christopher was receiving was appropriate and sufficient. The Polks sued in federal court, alleging that the school was violating the Education of the Handicapped Act (EHA) by failing to provide Christopher with an adequate education because the lack of physical therapy hindered his progress in meeting his educational goals. The district court granted summary judgment for the school, holding that because Christopher was still receiving some benefit from his education, the requirements of the EHA had been met. The Polks appealed.