K.L. v. RI Board of Education
907 F.3d 639
1st Cir.2018Background
- Plaintiff K.L., on behalf of a certified statewide class, challenged Rhode Island's policy ending IDEA FAPE at age 21 while the state funds adult education up to age 22 for non-disabled persons.
- District court held Rhode Island's adult-education programs were not "public education" under the IDEA and granted summary judgment to defendants (Rhode Island Board of Education and official).
- The core statutory provision: IDEA requires FAPE through age 21 but excepts ages 18–21 "to the extent" provision of FAPE would be "inconsistent with State law or practice respecting the provision of public education" (20 U.S.C. § 1412(a)(1)(B)(i)).
- The First Circuit construed the undefined phrase "public education" by reference to ordinary meaning, dictionaries, and IDEA context, identifying three attributes: significant public funding, public administration/oversight, and an objective to educate through the level associated with secondary school completion.
- On the facts, Rhode Island funds (~80%) and oversees community-based adult-education providers that prepare learners for GED/NEDP equivalency (including persons aged 21–22). The court held these programs satisfy the three attributes and thus constitute "public education," triggering FAPE through age 22.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of "public education" in § 1412(a)(1)(B)(i) | "Public education" includes state-funded/overseen adult-education programs that help learners reach secondary-level competency | "Public education" is limited to traditional public schools (preschool, elementary, secondary) controlled and delivered in school settings | Court: "Public education" = (1) significant public funding, (2) public administration/oversight, and (3) education up to secondary-school-level competence; not limited to traditional school buildings |
| Whether Rhode Island's adult-education programs are "public education" under IDEA | RI adult-education CBOs are largely publicly funded, overseen by RIDE, and aim to achieve secondary-level competencies (GED/NEDP), so they are public education | Programs are nontraditional, partially fee-based, community-run, differ from K–12 curricula and schedules; thus not "public education" | Held: Rhode Island's adult-education CBOs meet the three attributes and therefore constitute "public education" for purposes of § 1412(a)(1)(B)(i) |
| Role of state law/practice in defining "public education" | The statutory reference to "State law or practice" limits application of FAPE if state does not provide public education in the 18–21 range, but it does not let states define "public education" differently from its ordinary meaning | State usage and statutes should inform the scope; states retain control to define their systems and whether adult education is "public education" | Held: States may show a practice of not providing public education in the age band, but they may not unilaterally redefine the federal term "public education." Rhode Island law is not dispositive for the federal definition here |
| Remedy and effect on state/local control | Plaintiff seeks extension of FAPE through the 22nd birthday for class members; remedy to be developed on remand | Defendants warn of significant fiscal and administrative burdens and intrusion on local control | Held: District court judgment vacated; judgment entered for K.L.; remanded for remedial proceedings to determine appropriate relief and implementation; the decision does not prescribe the exact service delivery mechanism |
Key Cases Cited
- L.A. Unified Sch. Dist. v. Garcia, 669 F.3d 956 (9th Cir.) (discusses entitlement to continued special-education services until age 22)
- St. Johnsbury Acad. v. D.H., 240 F.3d 163 (2d Cir.) (similar principle on continuation of services)
- E.R.K. ex rel. R.K. v. Hawaii Dep't of Educ., 728 F.3d 982 (9th Cir.) (analyzed § 1412(a)(1)(B)(i) and legislative history regarding public-education exception)
- United States v. Chuong Van Duong, 665 F.3d 364 (1st Cir.) (ordinary-meaning presumption for undefined statutory terms)
- Board of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (Sup. Ct.) (IDEA interpretation principles; caution about imposing judicial views of educational methods)
- Tcherepnin v. Knight, 389 U.S. 332 (Sup. Ct.) (remedial statutes construed broadly to effectuate purpose)