R.L. v. Miami-Dade County School Board
2014 U.S. App. LEXIS 12841
| 11th Cir. | 2014Background
- O.L. has developmental, anxiety and sensory-processing disorders; large high schools worsened his symptoms.
- Parents withdrew O.L. from the public system after the Board refused a smaller, suitable placement and arranged for one-on-one home instruction.
- IEP team in 2006 identified Palmetto Senior High School (a large school) as placement despite parents’ preference for a smaller setting like MAST Academy.
- ALJ found the May 2006 IEP not reasonably calculated to provide educational benefit; district court partially disagreed on suitability of Palmetto.
- District Court reimbursed parents for one-on-one home instruction and related Medicaid therapy, but denied compensatory education; board challenges these rulings.
- Court concludes IDEA allows reimbursement for home-based one-on-one instruction where appropriate and where the public program failed to offer a FAPE.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether eligibility for reimbursement was proper where the IEP did not provide a FAPE. | R.L. and S.L. argued the IEP deprived O.L. of a FAPE and thus reimbursement is warranted. | Board contends the IEP offered a FAPE or that any deficiency does not mandate reimbursement. | Eligible for reimbursement; IEP deficits depriving FAPE justify reimbursement. |
| Whether the one-on-one home instruction was an appropriate alternative. | The program provided educational benefits and aligned with O.L.’s needs. | Questioned the suitability of home instruction and its comparability to school-based services. | Yes; the one-on-one program was reasonably calculated to confer educational benefits. |
| Whether equitable considerations supported full reimbursement despite predetermination concerns. | Equities weigh in favor of reimbursement given the failure to provide FAPE. | Equities might reduce or deny reimbursement due to predetermination and process issues. | Equitable factors supported full reimbursement; predetermination did not bar relief. |
| Whether the district court properly denied compensatory education. | Compensatory education should address past deficiencies. | Parent-chosen alternative was not shown to be superior; no causal link established. | Denial of compensatory education affirmed. |
Key Cases Cited
- Bd. of Educ. v. Rowley, 458 U.S. 176 (Supreme Court, 1982) (IEP must be reasonably calculated to provide educational benefits)
- Florence Cnty. Sch. Dist. Four v. Carter, 510 U.S. 7 (Supreme Court, 1993) (Private placement only if proper under IDEA)
- Forest Grove Sch. Dist. v. TA, 557 U.S. 230 (Supreme Court, 2009) (Remedial power not exhausted by § 1412(a)(10)(C)(ii))
- Deal v. Hamilton Cnty. Bd. of Educ., 392 F.3d 840 (6th Cir., 2004) (Predetermination and meaningful parental participation standards)
- Loren F. v. Atlanta Indep. Sch. Sys., 349 F.3d 1309 (11th Cir., 2003) (Judgment on the record; deference to ALJ but not blind)
- M.M. v. Sch. Bd. of Miami-Dade Cnty., Fla., 437 F.3d 1085 (11th Cir., 2006) (Reimbursement framework for failure to provide FAPE; two-step analysis)