Taylor v. Vermont Department of Education
United States Court of Appeals for the Second Circuit
313 F.3d 768 (2002)

- Written by Carolyn Strutton, JD
Facts
L.D. was a child with an emotional-behavioral disability whose parents were divorced. Under a divorce decree issued by a Vermont family court, L.D.’s father was granted all legal rights and authority to make educational decisions for L.D. and to participate in her education. L.D.’s mother, Pam Taylor (plaintiff) was only granted the right to receive information about L.D.’s educational progress. Taylor eventually disagreed with L.D.’s father and the school district about aspects of L.D.’s education plan. Taylor demanded an independent education evaluation of L.D., a right granted to parents under the Individuals with Disabilities Education Act (IDEA). L.D.’s father and the district opposed conducting this evaluation, so Taylor’s request was denied. Taylor attempted to initiate administrative appeals regarding details of L.D’s education, but these were also denied, on the grounds that Taylor lacked standing to bring such claims. Taylor then brought a suit in federal district court against the Vermont Department of Education (defendant), claiming violations of the IDEA with respect to L.D.’s education as well as for access to L.D.’s educational records. The district court dismissed Taylor’s claims for lack of standing, and Taylor appealed.
Rule of Law
Issue
Holding and Reasoning (Sotomayor, J.)
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