J.P. v. Belton School District No. 124, No. 21-3048 (8th Cir. 2022)

The parties to this matter—Plaintiff, on behalf of her son, and the Belton School District—disagree about the appropriate school placement for Plaintiff’s son pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. Section 1400 et seq. Plaintiff appealed the decision of the district court granting judgment on the administrative record to the District.
 
On appeal, Plaintiff asserts that transferring her son to Trails West would violate his right under the IDEA to be educated in the least restrictive environment (LRE). Alternatively, Plaintiff argued, if her son needs additional services, the District should provide them in her son’s current placement. Thus, the question is whether Kentucky Trail or Trails West is the LRE in which Plaintiff’s son can receive a free appropriate public education (FAPE).
 
The Eighth Circuit affirmed finding no clear error in the district court’s factual findings and agreed that a preponderance of the evidence supports the AHC’s conclusion that placement at Trails West respects Plaintiff’s son's rights under the IDEA. Second, although Plaintiff emphasizes the social benefit her son receives from his more integrated placement at Kentucky Trail, the evidence shows that her son receives all of his instruction in the special education classroom and eats lunch there as well, and he has contact with nondisabled peers only when passing in the hallways or at recess. Further, there was sufficient evidence to support the conclusion that placement at Trails West offers substantial benefits for Plaintiff’s son.