Minnetonka Public Schools v. M.L.K., No. 21-1707 (8th Cir. 2022)
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A child, through his parents, brought a due process challenge under the Individuals with Disabilities Education Act (IDEA), claiming that the School District failed to provide him a free appropriate public education (FAPE). An administrative law judge agreed and
ordered compensatory education. The district court affirmed but reduced the compensatory education award based on the statute of limitations. The parties cross-appealed. On appeal, the Eighth Circuit found that the school provided the child with a FAPE and reversed the district court's order.
Court Description: [Kobes, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Civil case - Individuals with Disabilities Education Act. The school district fulfilled its obligations to provide M.L.K. with a free appropriate public education (FAPE), and the district court's decision affirming the administrative law judge's finding that the school district had failed to do so and ordering it to provide compensatory education is reversed; M.L.K.'s lack of progress was not, as the district court concluded, due to the school district's misclassification of his primary disabilities; even if M.L.K. had been misclassified, he was not denied a FAPE because the school district created an Individualized Education Plan that was reasonably calculated to allow him to make appropriate progress in light of his circumstances.
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