D.E. v. Central Dauphin School District
765 F.3d 260
| 3rd Cir. | 2014Background
- D.E. (then 23) was a minor with a learning disability enrolled in Central Dauphin School District, with parents alleging IDEA FAPE violations and ADA/RA discrimination.
- CAIU placed D.E. in speech-language therapy pre-district; upon entering Central Dauphin, initial CER/IEP addressed only speech-language goals, while academics deteriorated and he repeated kindergarten.
- In 1996–1997, a new CER identified a learning disability and need for specially designed instruction; IEPs followed with learning support and speech-language services, though academic progress remained below grade level.
- Throughout early grades, D.E. faced placement in restrictive/incorrectly labeled programs, misclassifications, and periodic reevaluations; by seventh grade his math goal and support services were inconsistently maintained.
- A March 2006 due process hearing found IDEA and RA violations and awarded compensatory education; the district court later dismissed IDEA claims for exhaustion and then granted summary judgment on ADA/RA claims.
- The Third Circuit ultimately affirmed the ADA/RA ruling but reversed the dismissal of the IDEA claim, holding that enforcement of a favorable administrative decision does not require exhaustion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the district court err in granting summary judgment on ADA/RA claims? | D.E. argues deliberate indifference by Central Dauphin violated ADA/RA. | Central Dauphin asserts no deliberate indifference; evidence shows only evaluation/placement errors and negligence. | Affirmed summary judgment for ADA/RA; no deliberate indifference proven |
| Must a party exhaust administrative remedies to pursue IDEA claims where they seek to enforce a favorable order? | Enforcement of a favorable administrative award should not require further exhaustion. | Exhaustion is required unless an exceptional basis exists; here it does not. | Reversed district court; exhaustion not required to enforce a favorable IDEA decision |
| May a court provide or enforce an IDEA compensatory-education remedy that includes a fund or equitable mechanisms rather than mere reimbursement? | District failed to cooperate in creating a fund; remedy should not depend on fronting costs by parents. | Award language limits remedies to reimbursement and district payment options; fund creation is optional. | District Court erred by interpreting award to foreclose equitable fund remedy; held enforceable |
Key Cases Cited
- Becker v. Montgomery, 532 U.S. 757 (Supreme Court 2001) (curability of filing defects; timely signature can cure jurisdictional issues)
- Porter v. Bd. of Trs. of Manhattan Beach Unified Sch. Dist., 307 F.3d 1064 (9th Cir. 2002) (finality of an unfavorably appealed due process decision; exhaustion futile when no further remedies exist)
- Robinson v. Pinderhughes, 810 F.2d 1270 (4th Cir. 1987) (exhaustion not required where agency decision is final and no further appeal is available)
- Nieves-Marquez v. Puerto Rico, 353 F.3d 108 (1st Cir. 2003) (enforcement of favorable administrative orders; court may remedy continuing obligations)
- Dudley v. Lower Merion Sch. Dist., 768 F. Supp. 2d 779 (E.D. Pa. 2011) (enforcement and remedies under IDEA where school district fails to comply with favorable orders)
- Komninos v. Upper Saddle River Bd. of Educ., 13 F.3d 775 (3d Cir. 1994) (exhaustion requirement; IDEA's finality and need for administrative process)