Stephanie Johnson v. Charlotte-Mecklenburg Schools, 20 F.4th 835

Background

Plaintiff Stephanie Johnson filed IDEA administrative complaints alleging CMS denied her two children (A.J. and T.S.) a FAPE and sought evaluations and compensatory education.
Following administrative proceedings, CMS and the parents adopted a new IEP for A.J. and agreed to evaluate T.S.; the ALJ granted CMS summary judgment on multiple claims and found some claims moot; review officer partly affirmed and partly remanded for T.S.
Johnson then filed consolidated federal district-court actions under the IDEA seeking annulment/remand of administrative decisions and other relief, but did not expressly seek compensatory education in her federal complaints.
While the federal cases were pending, Johnson withdrew both children from CMS and enrolled them in another district.
The district court dismissed for lack of subject-matter jurisdiction, concluding prospective relief was moot and Johnson had not preserved a compensatory-education claim in federal court.
The Fourth Circuit affirmed: prospective relief against CMS was moot after withdrawal; compensatory education claims survive departure in principle, but here Johnson failed to plead that remedy in federal court, so no live controversy remained.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether prospective injunctive relief against CMS is moot after children withdraw	Johnson said she still sought relief (remand, corrective action) despite withdrawal	CMS argued district court cannot order future services for students no longer in its schools	Prospective relief is moot once students left CMS — court cannot grant future services against nonparty district
Whether a claim for compensatory education is moot when the student leaves the district	Johnson argued compensatory (backward-looking) relief survives withdrawal	CMS contended departure moots the entire case	Compensatory-education claims are not categorically moot after withdrawal; such claims can remain live because they remediate past harms
Whether Johnson’s federal complaint preserved a compensatory-education claim despite raising it in administrative proceedings only	Johnson said her administrative request and request for remand preserved compensatory relief	CMS said federal pleading controls and she did not seek that remedy in federal court	Plaintiff must plead compensatory education in the federal complaint (or allege facts reasonably implying it); Johnson did not, so federal claims were moot here
Whether a federal district court can remand IDEA cases to state agency to preserve/obtain remedies	Johnson argued remand to agency could vindicate compensatory relief she sought there	CMS relied on federal de novo nature of IDEA actions and district court authority	District courts exercise original, modified de novo review in IDEA cases and do not act as appellate remand courts; remand to state agency cannot substitute for pleading federal relief

Key Cases Cited

Endrew F. v. Douglas Cnty. Sch. Dist., 137 S. Ct. 988 (2017) (defines FAPE standard and requirement of individualized instruction)
Fry v. Napoleon Cmty. Schs., 137 S. Ct. 743 (2017) (distinguishes IDEA relief and related statutory frameworks)
G v. Fort Bragg Dependent Schs., 343 F.3d 295 (4th Cir. 2003) (recognizes compensatory education as equitable remedy for past FAPE denial)
D.F. v. Collingswood Borough Bd. of Educ., 694 F.3d 488 (3d Cir. 2012) (holds compensatory claims survive student’s departure and explains district liability for past transgressions)
Reid ex rel. Reid v. District of Columbia, 401 F.3d 516 (D.C. Cir. 2005) (compensatory education may include special programs to remedy prior deficiencies)
Kirkpatrick v. Lenoir Cnty. Bd. of Educ., 216 F.3d 380 (4th Cir. 2000) (IDEA actions in district court are original, not appellate; courts conduct modified de novo review)
Brown v. Bartholomew Consol. Sch. Corp., 442 F.3d 588 (7th Cir. 2006) (compensatory education is an exceptional equitable remedy; failure to request it in federal complaint can moot IDEA claims)
Me. Sch. Admin. Dist. No. 35 v. Mr. & Mrs. R., 321 F.3d 9 (1st Cir. 2003) (backward-looking compensatory claims can keep IDEA suits live after eligibility or enrollment ends)
Somberg v. Utica Cmty. Schs., 908 F.3d 162 (6th Cir. 2018) (aligns with circuits holding compensatory claims survive student withdrawal)