Osseo Area Schools, ISD 279 v. A.J.T., 96 F.4th 1062

A.J.T., a student with a rare form of epilepsy, cannot attend school before noon due to frequent morning seizures.
In Kentucky, her prior district provided evening instruction at home as part of her IEP; Osseo Area Schools (the District) in Minnesota refused to do so upon her family's relocation.
The District provided a shortened school day, ultimately offering only 3-4 hours of instruction, and repeatedly denied requests for evening instruction, citing administrative and policy concerns.
A.J.T.'s parents filed a complaint under the Individuals with Disabilities Education Act (IDEA), alleging denial of a free appropriate public education (FAPE).
An Administrative Law Judge and the district court found the District denied A.J.T. a FAPE; the District appealed to the Eighth Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether IDEA requires educational accommodations outside regular school hours	IDEA mandates services tailored to the student's needs, not limited to regular hours	IDEA does not compel education outside standard school times	IDEA covers necessary services beyond regular hours
Whether A.J.T.'s limited progress constituted denial of FAPE	A.J.T. made de minimis progress and regressed in areas like toileting	Minimal progress is significant for a disabled student; progress in some areas occurred	De minimis progress signals a denial of FAPE
Whether the removal of toileting goal from IEP was legally justified	Time constraints from shortened school days caused regression in toileting	Removal was justified due to lack of expected progress, not time limits	Constraint-driven removal of critical goals violated FAPE obligation
Whether considering potential benefit from evening instruction sets an improper standard	District's refusal to provide evening instruction based on administrative convenience, not maximizing potential	Considering evening instruction amounts to requiring maximization of student's potential	Inquiry was proper: administrative decisions causing lack of progress violate IDEA

Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. Dist. RE–1, 580 U.S. 386 (sets the FAPE standard as being more than de minimis progress, requiring IEPs reasonably calculated to allow appropriate progress)
Bd. of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (established basic FAPE requirements and the IDEA’s two-part test)
Hale ex rel. Hale v. Poplar Bluff R–I Sch. Dist., 280 F.3d 831 (discusses IDEA's stay-put provision)
Minnetonka Pub. Schs., Indep. Sch. Dist. No. 276 v. M.L.K. ex rel. S.K., 42 F.4th 847 (addresses standard of review in IDEA cases)
Petersen v. Hastings Pub. Schs., 31 F.3d 705 (court's role in reviewing IDEA cases is narrow)
Indep. Sch. Dist. No. 283 v. S.D. ex rel. J.D., 88 F.3d 556 (procedural inadequacy under IDEA is not a violation unless it causes lack of progress)
C.B. ex rel. B.B. v. Special Sch. Dist. No. 1, 636 F.3d 981 (importance of considering a student's individual needs when developing an IEP)