Justia Education Law Opinion Summaries

Appellant, a former student in the Forest Grove School District ("Forest Grove"), appealed the district court's determination that he was not entitled to an award of reimbursement for his private school tuition under the Individuals with Disabilities Education Act ("IDEA"), 20 U.S.C. 1415(i)(2)(C). At issue was whether the district court abused its discretion in holding that equitable considerations did not support any award of private-school tuition at Mount Bachelor Academy as a result of Forest Grove's failure to provide appellant with a Free and Appropriate Education ("FAPE") under the IDEA. The court held that the district court did not abuse its discretion in holding that there was sufficient evidence in the record to support the district court's factual determination where appellant's parents enrolled him at Mount Bachelor solely because of his drug abuse and behavioral problems.

Plaintiff, through his guardian, sued defendant, Garden Grove Unified School District ("District"), for reimbursement of the full costs of sending plaintiff to a non-public program when the District failed to provide a free appropriate public education to plaintiff. At issue was whether plaintiff was entitled to full reimbursement under the Individuals with Disabilities in Education Act ("Act")where the non-public program did not meet all of plaintiff's educational needs. The court held that plaintiff was properly awarded full reimbursement where the Act did not require that a private school placement provide all services that a disabled student needs in order to permit full reimbursement.