Richland School District v. Linda P. ex rel. Thomas P.

A high-school student (defendant) receiving special education for a learning disability under the Individuals with Disabilities Education Act (IDEA) participated in the vandalism of two elementary schools. The Richland School District (school district) (plaintiff) voted to expel the student based on a determination that the misconduct was not a manifestation of the student’s learning disability. The student’s mother requested a due-process hearing before an administrative law judge (ALJ) and hired a clinical psychologist. The psychologist testified about his diagnosis of the student with attention deficit disorder (ADD) and persistent depression that led to the student’s involvement in the vandalism incident. The ALJ set aside the school district’s expulsion because the student’s misconduct was a manifestation of these previously unidentified disabilities, even though the student was receiving special education for an identified disability. The school district brought suit in district court against the student and argued that the IDEA protections applied only to the student’s identified disability, which qualified the student for special education, and did not apply to the student’s unidentified ADD and persistent-depression disabilities. The school district sought reversal of the ALJ’s decision to set aside the student’s expulsion.