Roncker v. Walter

Neill Roncker (plaintiff) was a nine-year-old boy with severe mental disabilities in the State of Ohio (state) (defendant). Because of his disabilities, Roncker’s mental age was that of a two- or three-year-old. Roncker also suffered from seizures and required constant supervision due to an inability to recognize dangerous situations. Roncker was evaluated and believed to benefit from contact with nondisabled children. Roncker’s parents met with the school district (defendant) and several mental health professionals to create an individualized education program (IEP) for Roncker as required by the Individuals with Disabilities Education Act (IDEA), formerly known as the Education for All Handicapped Children Act. The district chose to place Roncker at a county school exclusively for mentally disabled children. Roncker’s family refused the placement and filed a due-process hearing. The hearing officer found that the district failed to show that its placement plan provided the maximum appropriate integration with nondisabled children and ordered Roncker placed in a special education class within a regular elementary school. The district appealed to the Ohio State Board of Education (board), which found that Roncker required the services in the county school but needed interaction with nondisabled students at lunch and recess. The board ruled that Roncker attend the county school and be provided access to nondisabled children, but the ruling did not indicate how to implement the split program. During the hearing process, Roncker attended a class for mentally disabled children at a regular public elementary school and was integrated with nondisabled students at lunch, recess, and gym. Roncker did not show substantial progress. Roncker’s mother filed suit against the state and the district, settling with the state outside of court. The district court ruled in favor of the school district, finding that the district had broad discretion to decide whether to mainstream disabled students and that the school did not abuse that discretion. Roncker appealed to the Sixth Circuit.