N.W. v. Boone Cnty. Bd. of Educ., No. 13-6514 (6th Cir. 2014)
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N., an autistic child, born in 2004, was diagnosed with the speech disorder, apraxia. In 2007, N.’s parents enrolled him in district schools, which placed him at St. Rita’s School for the Deaf under an individual education program (IEP). In 2010, N.’s parents became dissatisfied, removed N. from the school, unilaterally placed him at ABS (another Cincinnati private school), and requested reimbursement for the tuition and transportation. The district generated a new IEP. The district and N.’s parents could not agree on placement. Mediation resulted in the district agreeing to reimburse tuition and transportation expenses incurred from August 19, 2010 to November 30, 2010 and to pay a portion of the costs through the summer of 2011. The parties created a tentative transition plan, but N.’s parents balked at its implementation and filed a due-process complaint. A hearing officer rejected their claims, but ordered the district to reimburse the costs of attending ABS during the 2011–2012 school year. The Exceptional Children Appeal Board reversed that “stay-put” decision, holding that ABS was not N.’s “placement.” In a suit under the Individuals with Disabilities Education Act, 20 U.S.C. 1400–1482, the district court found that N. had not established that the offer of placement at a district school with an autism-specific classroom was inappropriate, but that N.’s operative placement was ABS, requiring reimbursement. The Sixth Circuit vacated in part. IDEA bars a court from ordering reimbursement absent a finding that the district failed to provide a free and appropriate public education.
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