Reid-Witt v. District of Columbia
Civil Action No. 2019-2473
| D.D.C. | Jul 28, 2021Background
- C.W., a student with anxiety and depression, attended Benjamin Banneker Academic High School (a selective DC public high school) and missed substantial school time and experienced hospitalizations related to her disability.
- Reid-Witt requested an IDEA Individualized Education Program; DCPS denied special-education eligibility and instead provided a Section 504 accommodation plan; DCPS recommended transfer out of Banneker when C.W.’s performance declined.
- An administrative hearing officer found C.W. had an emotional disturbance that adversely affected her education but concluded she did not need specially designed instruction to access the curriculum, reasoning Banneker was not part of DCPS’s "general curriculum" and that a transfer to a less rigorous school would suffice.
- Plaintiff sought review in federal court, challenging the IDEA denial and bringing disability-discrimination claims; the parties cross-moved for summary judgment on the IDEA claim.
- Plaintiff later submitted additional evidence (Banneker’s 2017 Blue Ribbon application showing it served special-education students). At oral argument the District conceded Banneker is part of the District’s general curriculum and asked for remand.
- The Court denied the cross-motions for summary judgment without prejudice and remanded to the hearing officer for further findings and conclusions in light of the District’s concession that Banneker is a general-curriculum school.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Banneker is a "general curriculum" school subject to the IDEA | Banneker is part of DCPS's general curriculum and must provide specially designed instruction to enable access | Banneker is a specialized school outside the systemwide general curriculum and thus not subject to IDEA special-education obligations | Court accepted District's on-the-record concession that Banneker is part of the general curriculum and remanded for reconsideration |
| Whether the hearing officer erred in denying IDEA relief by finding C.W. did not need special-education services to access the curriculum | Reid-Witt: hearing officer mischaracterized Banneker and lacked adequate findings on whether C.W. needs specially designed instruction at Banneker | DCPS (previously): C.W. could access curriculum in a more typical school and did not require specialized instruction at Banneker | Court did not resolve merits; remanded to hearing officer to weigh evidence under correct premise that Banneker is a general-curriculum school |
| Proper judicial relief: decide merits now or remand for more factfinding | Plaintiff favored judgment on current record | District requested remand after conceding Banneker is general curriculum | Court denied summary judgment motions without prejudice and remanded for additional findings and conclusions |
Key Cases Cited
- Bd. of Educ. v. Rowley, 458 U.S. 176 (establishes deference and scope of IDEA review)
- Reid v. District of Columbia, 401 F.3d 516 (D.C. Cir.) (allocation of burden and standard of review in IDEA cases)
- Kerkam v. McKenzie, 862 F.2d 884 (D.C. Cir.) (burden on party challenging administrative decision)
- Robinson v. District of Columbia, 637 F. Supp. 2d 11 (D.D.C.) (summary-judgment-as-judicial-review framework in IDEA cases)
- Taylor v. District of Columbia, 770 F. Supp. 2d 105 (D.D.C.) (remand for further administrative factfinding appropriate when record changed)
- Henry v. District of Columbia, 750 F. Supp. 2d 94 (D.D.C.) (district court discretion to remand to hearing officer)
- S.S. v. Howard Road Academy, 585 F. Supp. 2d 56 (D.D.C.) (limits on substituting court's educational policy judgments)