Munir v. Pottsville Area Sch. Dist.

Munir sent his son, O.M., to a private residential facility and a private boarding school after multiple suicide attempts, and sought reimbursement for the cost of the placements from the school district under the Individuals with Disabilities Education Act (IDEA), which requires that states receiving federal education funding ensure that disabled children receive a free appropriate public education, 20 U.S.C. 1412(a)(1) or pay for their education elsewhere if a child require specialized services that the public institution cannot provide. The district court denied the request, reasoning that O.M. had emotional problems, but that those problems were not affecting his ability to learn. The Third Circuit affirmed, finding that O.M.’s placement was to meet his mental health needs; any educational benefit he received from the placement was incidental. O.M. was an above-average student, without serious attendance problems, and socialized well in the district school. An individualized education plan offered by the district satisfied its IDEA obligations. View "Munir v. Pottsville Area Sch. Dist." on Justia Law