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Smith v. Robinson
United States Supreme Court
468 U.S. 992 (1984)
Tommy Smith (plaintiff) was an eight-year-old who suffered from cerebral palsy and several other physical and emotional disabilities. A dispute arose between Smith’s family and the state education system (defendant) over the appropriate school for Tommy and which state agency was responsible for funding his placement and associated services. Smith filed suit in federal district court against the state’s school committee, alleging violations of state law, the Education for All Handicapped Children Act (EHA) (later renamed the Individuals with Disabilities Education Act), the Rehabilitation Act, and the Due Process and Equal Protection Clauses of the Fourteenth Amendment. The Smiths’ legal theories centered on Tommy’s right to a free, appropriate special education. The Smiths’ lawsuit was effectively decided under the EHA, a statute that did not provide for recovery of attorney’s fees. The Smiths claimed that because they also brought other federal claims, they were entitled to attorney’s fees under 42 U.S.C. § 1988 and the Rehabilitation Act. The fee-recovery matter was appealed to the First Circuit and then the United States Supreme Court. The Supreme Court addressed whether a disabled plaintiff filing suit for his public-education right could circumvent or enlarge the listed EHA remedies by relying on other statutory and constitutional claims.
Rule of Law
Holding and Reasoning (Blackmun, J.)
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