Parrish v. Bentonville School District, No. 17-1915 (8th Cir. 2018)Annotate this Case
The Eighth Circuit affirmed the district court's grant of summary judgment to the school district and the Arkansas Department of Education, in an action alleging that plaintiffs' children were denied a free appropriate public education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA). The court held that Child A and Child L were provided a FAPE and the district court did not err in rejecting their families' claims. The court noted that the district court's strategies, while they might have been imperfect, complied with the IDEA, included detailed strategies to address the children's behavioral problems and contained evidence that the children were progressing academically. The court held that Child S and Child G's claims were not administratively exhausted and the district court properly granted the district's motion for summary judgment on their claims. Finally, the district court did not abuse its discretion by excluding an expert report as a sanction for plaintiffs' failure to disclose the report on a timely basis, and the report was conclusory and non-specific and would not have materially impacted the court's analysis.