Systema v. Academy School District No. 20

Nicholas Systema (plaintiff) was an autistic student in Academy School District No. 20 (district) (defendant). Once Systema turned three, the Individuals with Disabilities Education Act (IDEA) required the district to create an individualized education program (IEP) for Systema’s special education. In 2001, the district met with Systema’s parents to create a draft IEP. The written draft IEP included a weekly 10-hour placement in an integrated preschool classroom, supplemented by outside services. Systema’s parents refused the first draft over concerns about the integrated classroom. A few IEP team members met with Systema’s parents unofficially and offered to increase the IEP’s number of weekly service hours, but the district never formally amended the first draft of the IEP. Systema’s parents formally rejected the IEP draft after the unofficial meeting and continued Systema’s current at-home private schooling program. The district did not complete a final written IEP for Systema in 2001. Systema’s parents met with the IEP team in 2002 to create a program for the new year. Eventually, the district finalized an IEP and submitted it to Systema’s parents for approval. Systema’s parents refused to agree to or sign the 2002 IEP because it contained integrated classroom time. The family instead continued Systema’s at-home private schooling program and requested a due-process hearing to address the IEPs and to request tuition reimbursement for Systema’s private education. Systema’s parents argued that the school denied Systema his free appropriate public education (FAPE) by creating two deficient IEPs. The hearing officer found the IEPs to be appropriate and denied reimbursement, and on appeal an administrative-law judge (ALJ) affirmed the decision. The parents filed suit in federal district court. The court found that the 2001 IEP was procedurally deficient because it was unfinished and ordered reimbursement but affirmed the ALJ’s decision regarding the 2002 IEP. Both parties appealed to the Tenth Circuit, which found that the 2002 IEP was reasonably calculated to provide some educational benefit to Systema and did not violate the IDEA. The court then addressed the 2001 IEP.