Town of Burlington v. Department of Education for the Commonwealth of Massachusetts

John Doe (plaintiff) was a disabled student in the Town of Burlington (Burlington) (defendant). Doe’s parents sought administrative review of Doe’s individualized education program (IEP) and his educational placement. The Massachusetts Department of Education held a due-process hearing, and the hearing officer found that Burlington’s IEP was inadequate and inappropriate for Doe’s needs. The hearing officer ordered Burlington to pay private-school tuition for Doe. Burlington filed suit in federal district court against the state and Doe on federal- and state-law grounds, seeking to reverse the hearing officer’s order. Burlington requested to stay the order for tuition payment, but the district court denied the request. The district court granted summary judgment to Doe and the state. Burlington appealed to the First Circuit, which vacated the summary judgment, dismissed the state-law claims, and remanded the federal claims for trial. The district court reversed the hearing officer’s decision, finding that Burlington’s IEP was adequate and appropriate. Doe was ordered to reimburse Burlington for the private-school tuition it had paid. The state and Doe appealed to the First Circuit on multiple grounds. One claim stated that the district court did not properly give deference to the administrative record and improperly applied the provision of the Individuals with Disabilities Education Act (IDEA) that required additional evidence during judicial review. The First Circuit reversed the district court’s ruling in part, affirmed the ruling in part, and remanded the matter for trial. In its opinion, the appellate court addressed the required-deference and evidentiary standards the district court would need to apply on remand.