Doe v. Board of Educ. of State of Conn.
753 F. Supp. 65, 1990 U.S. Dist. LEXIS 17043, 1990 WL 201557 (1990)
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Rule of Law:
A child with emotional or behavioral problems does not qualify as a "handicapped child" entitled to special education under the Education of All Handicapped Children Act (EAHCA) unless their condition adversely affects their educational performance.
Facts:
- John Doe attended Darien public schools from kindergarten through fifth grade, performing well academically despite some documented behavioral issues.
- In January 1987, during his sixth-grade year, Doe's emotional condition worsened, leading his parents to hospitalize him for depression and violent outbursts.
- Upon his release from the hospital in May 1987, medical staff recommended placement in a residential treatment facility.
- Doe's parents unilaterally enrolled him at the Grove School, a private residential facility, and requested that the Darien Board of Education fund the placement.
- The Darien Board of Education proposed an Individualized Education Program (IEP) to be implemented within the public school system, which Doe's parents rejected.
- Throughout the period before, during, and after his hospitalization, Doe's academic performance, including grades and standardized test scores, remained satisfactory or above average.
Procedural Posture:
- John Doe's parents initiated state due process proceedings against the Darien Board of Education.
- A mediation held in February 1988 failed to resolve the dispute.
- An administrative hearing was conducted before a Connecticut state-appointed hearing officer in March and April 1988.
- On May 5, 1988, the hearing officer ruled that John Doe was not an 'exceptional child' under state law and was not entitled to special education.
- John Doe's parents, as his next friends, appealed the hearing officer's decision to the United States District Court for the District of Connecticut.
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Issue:
Does a child with significant emotional and behavioral problems qualify for special education services under the Education of All Handicapped Children Act (EAHCA) if those problems do not adversely affect the child's academic performance?
Opinions:
Majority - Chief Judge Ellen B. Burns
No. A child with significant emotional and behavioral problems does not qualify for special education services under the EAHCA if those problems do not adversely affect the child's academic performance. The court found that both federal and state law require an emotional disturbance to 'adversely affect educational performance' or 'significantly impede the child’s rate of educational development' to qualify a child for special education. Although John Doe had documented emotional difficulties, the evidence—including his consistently strong grades, test scores, and even testimony from his own psychiatrist—showed that his academic performance was not negatively impacted. Therefore, he did not meet the statutory definition of a 'handicapped child' in need of special education, and the school board was not required to fund his residential placement.
Analysis:
This decision clarifies a crucial limitation of the EAHCA, establishing that a medical or psychological diagnosis alone is insufficient to trigger a school district's obligation to provide special education. The ruling underscores that the Act's primary focus is on educational needs, requiring a clear causal link between a child's disability and a negative impact on their academic progress. This precedent forces parents and school districts to distinguish between purely medical/therapeutic needs and educational needs, potentially limiting public funding for residential placements for students who, despite emotional challenges, are academically successful.
