Alamo Heights Independent School District v. State Board of Education
790 F.2d 1153 (1986)
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Rule of Law:
Under the Education for All Handicapped Children Act (EAHCA), a school district must provide year-round educational services if a handicapped child will experience substantial regression without them. Transportation, as a related service, is not arbitrarily limited by school district boundaries and must be provided if reasonable and necessary for the child to benefit from their education.
Facts:
- Steven G. is a severely multiply handicapped child diagnosed with cerebral dysplasia, rendering him 'trainable' but not 'educable'.
- He lives with his mother, Beverly G., within the Alamo Heights Independent School District.
- In 1980, the School District, which previously offered summer programs, curtailed them and denied Beverly G.'s request for summer services for Steven.
- During the summer of 1980, while with an untrained babysitter, Steven regressed in his ability to stand, point, and feed himself.
- The following year, the School District again refused to provide summer services.
- Beverly G. also requested the School District provide after-school transportation for Steven to a caretaker's home located one mile outside the district boundary, as this was the only caretaker she could find.
- The School District refused to provide this out-of-district transportation.
Procedural Posture:
- Beverly G. appealed the School District's denial of services to the Texas Education Agency.
- An administrative hearing officer's process culminated in a final order requiring the School District to provide Steven with summer services and transportation.
- The Alamo Heights Independent School District (plaintiff) filed a complaint in federal district court to challenge the administrative order.
- The district court found in favor of Beverly G. and Steven (defendants), issuing an injunction requiring the School District to provide the requested services.
- The Alamo Heights Independent School District (appellant) appealed the district court's judgment to the U.S. Court of Appeals for the Fifth Circuit.
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Issue:
Does the Education for All Handicapped Children Act (EAHCA) require a school district to provide (1) summer educational programming for a severely handicapped child who will experience substantial regression of skills without it, and (2) transportation to a location a short distance outside the district's boundaries when necessary to assist the child in benefiting from their special education?
Opinions:
Majority - Rubin, J.
Yes. The EAHCA requires a school district to provide a free appropriate public education sufficient to confer 'some educational benefit,' and this may necessitate services beyond the standard 180-day school year. If a child will experience severe or substantial regression during the summer months without a program, such that the benefits accrued during the regular school year will be significantly jeopardized, the child is entitled to year-round services. The district court's finding that Steven G. would suffer substantial regression was supported by the record, justifying the order for summer programming. Furthermore, transportation is a 'related service' under the Act required to assist a handicapped child to benefit from special education. This service is not arbitrarily limited by geographic boundaries; unless the request is shown to be unreasonable or burdensome, the Act requires that such transportation be provided.
Analysis:
This case clarifies the standard for providing Extended School Year (ESY) services under the EAHCA, establishing that a district's obligation is triggered not by a total lack of progress, but by the threat of substantial regression that would jeopardize the educational benefits gained during the school year. It solidifies the principle that educational programming decisions must be individualized, rejecting blanket policies against summer services. The ruling also sets a precedent for the provision of 'related services' like transportation, holding that they must be flexible and reasonable, potentially extending beyond district lines to meet a child's unique needs without an affirmative showing of undue burden by the district.
