Springer v. Fairfax County School Board

Edward Springer (plaintiff) was a student in the Fairfax County school system (school board) (defendant). Before the eleventh grade, Springer maintained average to above-average grades, fostered positive social relationships with peers and teachers, and participated in school extracurricular activities. Springer showed no need for special education services or programs. During his junior year, Springer developed significant behavioral issues. Springer was arrested twice, frequently stole, engaged in drug and alcohol use with his friends, broke school rules, and consistently ditched classes. After missing his final exams, Springer failed three of his seven classes for the year. Springer’s family enrolled Springer in a private school for his next school year and requested that the school board provide the tuition, claiming that Springer had a serious emotional disturbance and was a disabled student under the Individuals with Disabilities Education Act (IDEA). The school board refused, and the Springers requested a due-process hearing. Springer was evaluated by multiple psychologists, and each one found that Springer was not seriously emotionally disturbed. However, the hearing officer found that Springer should be considered emotionally disturbed under the IDEA, basing the decision exclusively on a psychiatrist’s letter to juvenile court during one of Springer’s arrests. The school board appealed to a state review officer (SRO), who reversed the hearing officer’s decision and found that although Springer was socially maladjusted and had a conduct disorder, he showed no signs of a serious emotional disturbance. The Springers filed suit in federal district court to reverse the SRO’s decision, but the district court affirmed the ruling. The Springers appealed to the Fourth Circuit.