Reid v. District of Columbia

Mathew Reid was a teenager with learning disabilities, including dyslexia and attention-deficit hyperactivity disorder. Mathew received special-education services under the Individuals with Disabilities Education Act (IDEA) from the District of Columbia Public Schools (the district) (defendant). The district had initially delayed testing Mathew for disabilities, however, and he continued to have serious academic struggles. When the district proposed reducing some of the special-education services he received, Mathew’s mother, Ms. Reid (plaintiff) brought an administrative appeal, arguing that Mathew required a full-time special-education placement. Ms. Reid also argued that Mathew was entitled to compensatory education to make up for the deficiencies in the special-education services that Mathew had received from the district over the years. A hearing officer concluded that Mathew had been denied a free appropriate public education (FAPE) as required under the IDEA for roughly four and a half years and was entitled to compensatory education for that period. The hearing officer awarded one hour of compensatory education for each day of that period, for a total of 810 hours, but did not articulate why he used that formula for determining the award. Ms. Reid appealed the decision to the district court, seeking an increase in the number of hours awarded. Ms. Reid and the district filed cross-motions for summary judgment. The court granted summary judgment to the district and affirmed the award. Ms. Reid again appealed.