J.M. v. Weakley County Board of Education, 1:13-cv-01060

Student H.M., born 1989, experienced childhood sexual abuse and longstanding depression/PTSD; school performance declined in high school with truancy and acting-out.
In 2004–05 H.M. received psychiatric treatment (diagnoses including PTSD and major depression), was placed on medication, and received homebound instruction; WCS IEP team in Feb. 2005 found her not eligible as "emotionally disturbed."
H.M. later ran away, was sexually assaulted again, placed in residential treatment (Three Springs, then High Frontier), where she was certified as Emotionally Disturbed and later graduated with honors.
Parents previously obtained an ALJ ruling (Reynolds) finding procedural violations and entitlement to reimbursement; remand was ordered to determine whether H.M. met IDEA "emotional disturbance" criteria.
On remand ALJ Summers (on the record) concluded H.M. was "socially maladjusted," not emotionally disturbed; plaintiffs appealed.
District court reviewed de novo and concluded the preponderance of the evidence showed H.M. had marked, long-standing major depression that adversely affected education; it reversed ALJ Summers and remanded for further proceedings (including Section 504 if appropriate).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether H.M. was a "child with a disability" under IDEA via "emotional disturbance"	H.M. suffered marked, long-standing depression/PTSD that adversely affected educational performance; ALJ’s finding was erroneous	WCS argued H.M. was socially maladjusted (truancy, manipulative conduct) and did not meet the regulatory criteria for emotional disturbance	Court held H.M. met the emotional disturbance criteria (general pervasive mood of unhappiness/depression); reversed ALJ Summers and remanded
Whether district should defer to prior ALJ Reynolds’s findings	Plaintiffs urged deference to credibility determinations by ALJ Reynolds	WCS relied on ALJ Summers’s record-based decision and IEP team findings	Court found no Reynolds findings on emotional disturbance (he had not made those specific findings), so deference was limited and Summers’ selective reasoning received little weight
Whether ADA claim should proceed	Plaintiffs alleged ADA violations	WCS defended; briefs omitted ADA arguments at decision stage	Court dismissed ADA claim as abandoned (no trial-brief support)
Scope of remand and further proceedings	Plaintiffs sought remand to vindicate relief and address Section 504	WCS sought to defend original eligibility denial	Court remanded to ALJ to proceed consistent with opinion and to consider preclusive effect of earlier decisions and Section 504 if properly before ALJ

N.W. ex rel. J.W. v. Boone Cnty. Bd. of Educ., 763 F.3d 611 (6th Cir. 2014) (sets out modified de novo review standard for IDEA appeals)
Woods v. Northport Pub. Sch., [citation="487 F. App'x 968"] (6th Cir. 2012) (district court must independently re-examine administrative record but not substitute its educational policy views)
Springer v. Fairfax County Sch. Bd., 134 F.3d 659 (4th Cir. 1998) (explains distinction between "social maladjustment" and "emotional disturbance")
Carlisle Area Sch. v. Scott P., 62 F.3d 520 (3d Cir. 1995) (discusses weight to accord credibility findings by hearing officers on appeal)