Independent School District No. 283 v. E.M.D.H., No. 19-1269 (8th Cir. 2020)
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A student and her parents filed suit against the Minnesota Department of Education, alleging that the school district's failure to classify the student as disabled denied her the right to a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The ALJ concluded that the school district's treatment of the student violated the IDEA and related state special-education laws. The district court then denied the school district's motion for judgment on the administrative record and granted, in part, the student's motion for judgment on the record, modifying the award of compensatory education.
The Eighth Circuit held that the district court did not abuse its discretion in denying the school district's request for supplementation of the record; the school district's evaluation of the student was insufficiently informed and legally deficient; the student is eligible for special education and a state-funded FAPE like every other child with a disability; the ALJ and the district court did not err in concluding the school district had breached its obligation to identify the student by the spring of her eighth-grade year as a child eligible for special education; and the district court did not err in finding plaintiffs were entitled to recover the costs associated with comprehensive psychological evaluation, educational evaluation and private educational services. However, the court reinstated the ALJ's award of compensatory education costs.
Court Description: [Erickson, Author, with Grasz and Kobes, Circuit Judges] Civil case - Individuals with Disabilities Education Act. The district court's refusal to allow the school district to supplement the record with information regarding the student's performance since the ALJ's decision was not an abuse of the district court's discretion; the district court did not err in finding defendant had failed to provide the student with the full and sufficiently comprehensive evaluation required by the IDEA and Minnesota law; the record established the student was eligible for special education and a state-funded FAPE; the ALJ and the district court did not err in concluding the school district had breached its obligation to identify the student by the spring of her eighth-grade year as a child eligible for special education; the district court did not err in finding plaintiffs were entitled to recover the costs associated with comprehensive psychological evaluation, educational evaluation and private educational services; the court erred in determining plaintiffs were not entitled to an award of compensatory education in the form of private tutoring until the student earns the credits expected of her same-age peers.
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