Van Duyn v. Baker School District 5J

Christopher Van Duyn was a severely autistic child who received special education in Baker School District 5J (the district) (defendant). Christopher had an individualized education program (IEP) during elementary school that was carried over to his first year of middle school. The IEP included specific guidance for particular subjects, as well as a behavior-management plan. Once Christopher was in middle school, however, the school failed to implement the provisions of the IEP exactly as the IEP provided. The primary failures in implementation were a reduction in the amount of math instruction and changes in the behavior-management plan. Christopher made overall progress behaviorally and academically during the year. Christopher’s parents (the Van Duyns) (plaintiffs) brought an administrative claim alleging that the district had failed to adequately implement Christopher’s IEP and therefore had violated the Individuals with Disabilities Education Act (IDEA). The administrative-law judge held that the district had failed to provide Christopher with adequate math instruction but otherwise had adequately implemented the IEP. The district increased Christopher’s math instruction in response to this ruling. The Van Duyns appealed the ruling in federal district court. The district court affirmed the administrative ruling, and the Van Duyns appealed.