Seattle School District v B.S.

1
Seattle School District v B.S.

• 82 F.3d 1493 (9th Cir. 1996)

2
Relevant Facts

• BSs child (AS) had severe behavioral problems
  that resulted in her expulsion from school.
• Seattle School District determined that AS was
  eligible for special services, but that she could
  be mainstreamed.
• BS obtained an independent evaluation by a child
  psychiatrist, who concluded that a residential
  facility was necessary.
• BS enrolled AS in a residential facility in
  Montana and filed an action for a due process
  hearing.
• BS wanted the Seattle School District to pay for
  ASs treatment at the residential facility.

3

• An administrative law judge ruled that the
  District had violated the Individuals with
  Disabilities and Education Act.
• The School District appealed to the federal
  district court.
• The district court affirmed the decision and
  ordered the School District to reimburse BS for
  the costs of the evaluation and of the
  residential facility.
• The district court found that the School
  Districts educational plan was inadequate and
  that the residential program in Montana was an
  appropriate placement

Procedure
4
Issues

• Whether the School Districts evaluation of A.S.
  was sufficient.
• Whether, under IDEA, mainstreaming was
  appropriate for A.S.
• Whether the School District should be responsible
  for the costs of the residential placement
  because of the medical nature of the facility.

Issues
5

• Under the IDEA, an assessment team that does not
  include anyone with knowledge in the disorders
  that cause a students problems is insufficient.
• The School Districts failure to properly staff
  the assessment team directly conflicted with
  federal regulations.
• When a school districts evaluation is not
  appropriate, the student is entitled to an
  independent evaluation at public expense.
• The School Districts own evaluation was
  insufficient and the parents would have no
  recourse if the School District could ignore an
  independent evaluation.

Holdings Reasoning
6

• Under the IDEA, if a student is unable to derive
  any meaningful educational benefit in a regular
  classroom, then that student is denied an
  appropriate education.
• IDEA obligates states to provide a basic floor of
  opportunity.
• IDEA explicitly authorizes placement in
  residential programs

Holdings Reasoning
7

• The residential placement was appropriate
• By the time the case was in district court, A.S.
  had been at the facility for seven months and was
  making progress
• The school district failed to provide experts and
  A.S. provided several experts.
• IDEA does not require mainstreaming before
  moving to more restrictive environments.
• The School District never proposed an alternative
  placement appropriate for A.S.

Holdings Reasoning
8

• Under the IDEA, a residential program that
  addresses underlying medical disorders can still
  qualify as an educational program that a School
  District needs to pay for.
• Most disabilities stem from medical or
  psychiatric disorders. It would be ridiculous to
  forbid a residential program from attempting to
  treat an underlying problem.

Holdings Reasoning
9

• Residential placement, rather than mainstreaming,
  may be appropriate for a disabled student with
  emotional disorders.
• Placement of the student in an out-of-state
  facility may be appropriate if that facility is
  the closest available location for appropriate
  treatment.
• The fact that a residential facility addresses
  the child's medical or psychiatric disorders does
  not render the program offered by the facility a
  "medical" program inappropriate for placement
  under IDEA or remove the school district's
  financial responsibility for the non-medical
  costs of the placement.

Significance