D. L. v. Baltimore City Bd. of Sch. Comm., No. 11-2041 (4th Cir. 2013)Annotate this Case
Plaintiffs, D.L. and his parents, appealed the district court's grant of summary judgment to the BCBSC and Baltimore City Public Schools, contending that Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794, compelled BCBSC to provide D.L. education services related to certain disorders even though D.L. was enrolled exclusively in a private religious school. Because plaintiffs retained full discretion over school enrollment and because BCBSC has taken reasonable measures to fulfill its mission, the court found that BCBSC's policies placed no undue burden on plaintiffs' constitutional rights. Because the court did not read Section 504 to apply an affirmative obligation on school districts to provide services to private school students and because plaintiffs retained full educational discretion, the court affirmed the district court's ruling.