Schaffer v. Weast

In 1997, Brian Schaffer (plaintiff), a child with learning disabilities and speech-language impairments, planned to enter Montgomery County Public Schools System (MCPS) as an eighth-grader. MCPS convened an individualized-education-program (IEP) team for Brian, which was mandated by the Individuals with Disabilities Education Act (IDEA). Brian’s parents (the Schaffers) rejected MCPS’s initial IEP proposal; the Schaffers felt that Brian needed smaller classes and more intensive services. Instead, the Schaffers placed Brian in private school and initiated a due-process hearing to challenge the IEP. In Maryland, administrative law judges (ALJs) conduct IEP hearings. After a three-day hearing, the ALJ ruled in favor of MCPS, reasoning that the Schaffers had failed to meet their burden of persuasion. The Schaffers challenged the ALJ’s findings in federal district court, specifically suing MCPS’s superintendent, Jerry Weast, and MCPS’s Board of Education (defendants). During the federal-court proceedings, the Schaffers accepted MCPS’s offer to place Brian in a high school with a special learning center. However, the lawsuit continued because the Schaffers also sought reimbursement for Brian’s private-school costs. The district court reversed and remanded the case to the ALJ, finding that MCPS had the burden of persuasion. Notably, Maryland law did not specify which party bore the burden of persuasion in administrative proceedings regarding IEPs. After reconsidering the case, the ALJ ruled in favor of the Schaffers, emphasizing that the evidence was truly balanced, so MCPS had failed to meet its burden of persuasion. Eventually, the United States Court of Appeals for the Fourth Circuit reversed, finding that the Schaffers, as the party who sought relief, should have had the burden of persuasion. The United States Supreme Court granted certiorari to resolve the burden-of-persuasion dispute.