Florence County School District Four v. Carter Ex Rel. Carter
510 U.S. 7, 1993 U.S. LEXIS 7154, 126 L. Ed. 2d 284 (1993)
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Rule of Law:
Under the Individuals with Disabilities Education Act (IDEA), a court may order a school district to reimburse parents for the cost of a unilateral private school placement, even if the private school does not meet all state educational standards, so long as the public school's proposed Individualized Education Program (IEP) was inappropriate and the private placement was proper and reasonably calculated to enable the child to receive educational benefits.
Facts:
- Shannon Carter, a ninth-grade student in Florence County School District Four, was classified as learning disabled in 1985.
- The school district formulated an Individualized Education Program (IEP) for Shannon which her parents found unsatisfactory, as it aimed for only four months of progress over an entire school year.
- While challenging the IEP's adequacy through administrative channels, Shannon's parents unilaterally withdrew her from public school.
- They enrolled Shannon in Trident Academy, a private school specializing in educating children with disabilities.
- Trident Academy did not meet all state standards; for example, it employed some teachers who were not state-certified and did not develop IEPs in the manner prescribed by IDEA.
- Shannon attended Trident from 1985 to 1988, where she made significant progress, including improving her reading comprehension by three grade levels.
Procedural Posture:
- Shannon Carter's parents requested an administrative hearing to challenge the school district's proposed IEP.
- The local and state educational hearing officers both concluded that the IEP was adequate.
- The Carters filed a lawsuit in the United States District Court against Florence County School District Four, seeking reimbursement for tuition and costs at Trident Academy.
- Following a bench trial, the District Court found the school's IEP wholly inadequate, ruled that Trident provided an appropriate education, and ordered the school district to reimburse the Carters.
- Florence County School District Four, as appellant, appealed the decision to the U.S. Court of Appeals for the Fourth Circuit.
- The Court of Appeals affirmed the District Court's judgment in favor of the Carters (appellees).
- The U.S. Supreme Court granted certiorari to resolve a conflict among the circuit courts on this issue.
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Issue:
Does the Individuals with Disabilities Education Act (IDEA) permit a court to order a school district to reimburse parents for the cost of a private school placement when the public school failed to provide a free appropriate public education (FAPE), even if the private school does not meet all the statutory requirements for a FAPE?
Opinions:
Majority - Justice O'Connor
Yes. A court may order reimbursement for a unilateral parental placement in a private school that does not meet the statutory definition of a 'free appropriate public education.' The requirements for a FAPE outlined in § 1401(a)(18) of IDEA—such as being under public supervision and meeting state standards—are obligations imposed on public schools and do not apply to a private school placement chosen by parents after the public school has defaulted on its duty. To apply these public-school-centric requirements to parental placements would effectively eliminate the reimbursement remedy recognized in School Comm. of Burlington v. Department of Ed. of Mass., as parents only resort to such placements when the public system fails. The purpose of IDEA is to ensure children with disabilities receive an appropriate education, and it would be inconsistent with the Act's goals to allow a school system that failed to provide such an education to use its own state-approval standards as a shield against reimbursing parents for a placement that was, in fact, appropriate.
Analysis:
This decision significantly strengthens the rights of parents under IDEA by clarifying and expanding the tuition reimbursement remedy established in Burlington. It ensures that the primary focus in reimbursement cases is on the substantive appropriateness of the education provided, rather than the private school's strict compliance with state bureaucratic requirements. By removing the state-approval requirement as a bar to reimbursement, the ruling places the financial risk squarely on school districts that fail to offer an appropriate education, thereby incentivizing them to create adequate IEPs from the outset. This holding empowers parents to seek effective educational alternatives for their children without the fear that a technical non-compliance by the private school will prevent them from being reimbursed for a placement that the public school should have provided.
