Thompson R-2J School District v. Luke P.

Luke P. (plaintiff) was a child with autism who attended public school from kindergarten through second grade in the Thompson R2-J School District (Thompson) (defendant). Although Luke made progress at school, his autism resulted in severe behavioral problems away from school. Luke was unevenly tempered and displayed inappropriate and sometimes violent behavior at home and in public places. Luke developed sleeping problems, waking up frequently in the night and refusing to sleep in a bed. By first grade Luke was toilet trained at school, but he was unable to transfer this skill to his home and other settings away from school. Out of concern that without intervention Luke’s behavior would become more dangerous as he grew physically, Luke’s parents withdrew Luke from the public school he attended and enrolled him in a private residential program. Luke, through his parents, brought suit against Thompson, seeking reimbursement of Luke’s tuition costs. Because of the difficulty Luke had experienced with generalizing the skills learned in school to his home and other environments, Luke’s parents asserted that Thompson failed to provide Luke with the educational services required by the Individuals with Disabilities Education Act (act). They also asserted that only a private residential school could provide Luke with an adequate education because of the severity of the manifestations of Luke’s disability. Every fact-finder who had assessed the case found that Luke was making progress in the public-school environment on the educational goals individually formulated for him by Thompson and Luke’s parents.