D. L. v. St. Louis City School District, No. 18-3444 (8th Cir. 2020)
Annotate this Case
Plaintiffs filed suit under the Individuals with Disabilities Education Act (IDEA), bringing a due process challenge to the school district's individualized education plan (IEP) and school placement before the Missouri Administrative Hearing Commission. The Commission affirmed the plan and placement, denying reimbursement. The district court reversed the Commission but limited the reimbursement award based on equitable considerations.
The Eighth Circuit held that the school district violated the IDEA and the district court erred in limiting the award. As a preliminary matter, the court held that the school district's jurisdictional challenge was without merit; the school district's mootness challenge also failed; and the district court properly placed the burden on plaintiffs in the proceeding before it and correctly stated the standard of review on appeal.
On the merits, the court held that the school district denied plaintiffs' son a free and appropriate education as required by the IDEA when it placed him at a school without direct occupational therapy or a sensory diet plan in place to address his autism-related issues. The court also held that an award limitation based on improvements to the school was inappropriate and inconsistent with the purposes of the IDEA because the school district failed to give any notice to plaintiffs. Furthermore, limiting an award based on improvements not communicated to plaintiffs was inconsistent with the IDEA's purpose. Accordingly, the court reversed the district court's limitation of tuition reimbursement and awarded full tuition reimbursement.
Court Description: [Erickson, Author, with Melloy and Kobes, Circuit Judges] Civil case - Individuals with Disabilities Education Act. The District's jurisdictional challenge was without merit because the student was enrolled in the City School District at the time the complaint was filed, had not yet enrolled in a private school setting and his parents had provided the school with notice; plaintiff sought compensation for past obligations, rather than prospective relief, and his claims were not moot because he no longer resided in the District; district court's misstatement of the burden of proof was immaterial as it merely incorrectly described a past proceeding and the court properly placed the burden of proof and applied the correct standard of review in the proceeding pending before it; the district court did not err in determining the District had denied plaintiff and Free Appropriate Public Education when it placed him at a school without direct occupational therapy or a sensory diet plan to address his autism-related issues; the district court erred in limiting its tuition reimbursement award based on improvements the District had made to plaintiff's school as those improvements were not communicated to plaintiff's parents; the limitation of tuition reimbursement is reversed and the matter is remanded with directions to award plaintiff full reimbursement for his attendance at a private school.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.