Cedar Rapids Community School District v. Garret F. Ex Rel. Charlene F.
1999 U.S. LEXIS 1709, 526 U.S. 66, 143 L. Ed. 2d 154 (1999)
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Rule of Law:
The Individuals with Disabilities Education Act (IDEA) requires a public school district to provide supportive services, including continuous one-on-one nursing services, that are necessary for a disabled child to access their education, so long as those services do not need to be performed by a licensed physician. The cost or intensity of the services does not make them excludable "medical services."
Facts:
- At four years old, Garret F. was in a motorcycle accident that severed his spinal column, leaving him paralyzed from the neck down but with unaffected mental capacities.
- Garret is ventilator-dependent and requires a range of services during the school day, including urinary bladder catheterization, tracheotomy suctioning, and management of his ventilator.
- He attends regular classes in the Cedar Rapids Community School District and has been successful academically.
- For several years, Garret's family paid for a licensed practical nurse to attend to his needs during the school day.
- In 1993, Garret’s mother requested that the Cedar Rapids Community School District assume financial responsibility for the nursing services he required to attend school.
- The District denied the request, asserting it was not legally obligated to provide continuous one-on-one nursing services.
Procedural Posture:
- Garret F.'s mother requested an administrative hearing before the Iowa Department of Education.
- An Administrative Law Judge (ALJ) concluded that the IDEA required the District to bear financial responsibility for the services.
- The District challenged the ALJ's decision by filing suit in the U.S. District Court.
- The U.S. District Court, a trial court, granted summary judgment against the District and approved the ALJ's ruling.
- The District, as appellant, appealed the decision to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals, an intermediate appellate court, affirmed the District Court's judgment in favor of Garret F.
- The Supreme Court of the United States granted the District's petition for a writ of certiorari to resolve a conflict among the federal courts of appeals.
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Issue:
Does the definition of "related services" under the Individuals with Disabilities Education Act (IDEA) require a public school district to provide a student with continuous one-on-one nursing services that can be delivered by a nurse, rather than a physician?
Opinions:
Majority - Justice Stevens
Yes. The IDEA requires the school district to provide these continuous nursing services because they do not have to be performed by a physician and are necessary for the student to access his education. The Court reaffirmed the bright-line test from Irving Independent School Dist. v. Tatro, which holds that services excluded as "medical services" are limited to those that must be performed by a licensed physician. Services that can be provided by a nurse or other qualified layperson are considered required "related services." The District's proposed multi-factor test, which considers the cost, continuity, and potential risks of the services, is not supported by the statute's text. The continuous character of the services does not make them more "medical," and while the financial burden on the district may be significant, cost is not a factor in the statutory definition of "medical services." The purpose of the IDEA is to provide meaningful access to education, and Garret cannot remain in school without these services.
Dissenting - Justice Thomas
No. The IDEA does not require the school district to fund continuous, one-on-one nursing care. The Court's decision in Tatro was wrongly decided because it improperly focused on the provider of the service rather than the nature of the service itself. The continuous, life-sustaining services Garret requires are inherently "medical services" regardless of who administers them, and should be excluded under the plain text of the IDEA. Furthermore, because the IDEA is Spending Clause legislation, it must be interpreted narrowly to avoid placing unanticipated and ambiguous financial obligations on the states. The majority's holding imposes a burden of "unspecified proportions and weight" on school districts, turning them into healthcare providers and blindsiding states with fiscal obligations they could not have anticipated.
Analysis:
This decision solidifies the bright-line test from Tatro, clarifying that the determination of a "related service" versus an excludable "medical service" hinges solely on whether a physician is required. The Court explicitly rejected cost and service intensity as factors, significantly impacting school districts by requiring them to fund potentially expensive, continuous care for students with severe disabilities. This precedent prevents lower courts from creating an "undue burden" exception based on cost and reinforces the IDEA's core purpose of ensuring meaningful educational access, even for students with the most complex medical needs.
