Background
C.T., an elementary school student with disabilities including attention deficit hyperactivity disorder and sensory disturbances, was placed in a self-contained emotional and behavioral disorders classroom. Three weeks later, the Galesburg Community Unit School District proposed an Individualized Education Plan to move C.T. to a private therapeutic day school in a different district, which would require a forty-five-minute bus ride and offer no mainstreaming opportunities. C.T.’s parents requested a due process hearing, which concluded the district had complied with the Act. The district court then conducted a bench trial, heard new evidence regarding C.T.’s progress and the need for a one-on-one aide, and reversed the hearing officer’s decision.
The court’s reasoning
The Seventh Circuit reviewed the district court’s decision for clear error, noting that the district court received significant new evidence at a bench trial, which reduced the deference owed to the administrative hearing officer’s findings. The court applied the two-step framework for Least Restrictive Environment analysis, treating the inquiry as whether C.T. could receive a satisfactory education in the less restrictive EBD classroom with additional reasonable measures. The court found no clear error in the district court’s conclusion that C.T. had made significant progress, formed positive relationships, and would benefit from a one-on-one aide, which the school district had failed to adequately justify.
What it means going forward
School districts must ensure that students with disabilities are educated in the least restrictive environment possible and cannot move a student to a more restrictive setting without demonstrating that the less restrictive setting cannot provide a satisfactory education even with supplementary aids and services.
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