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Jonathan is a tenth-grade student who has multiple disabilities that wants to attend a
public school in his local school district. Jonathan has several severe disabilities including being
profoundly mentally disabled, has spastic quadriplegia, and also has a seizure disorder. Due to
his disorders, Jonathan requires constant care by a specially trained nurse. His parents meet with
Debbie Young, a high school principal, to discuss getting Jonathan enrolled. Debbie Young had
previously been a special education teacher and ended up denying the parents’ request to be
placed in the school district. Her reasoning was because of Jonathan’s disabilities, the school
was not the most appropriate placement for him and it would also place an extraordinary
financial burden on the school in order to accommodate him. There have been several court
cases that have dealt with similar issues with varying results.
In Board of Education of the Hendrick Hudson Central School District v. Rowley, the
Supreme Court set the precedent for whether or not a school district had met the requirements of
a free and appropriate public education. In this case a deaf elementary school student named
Amy Rowley had been receiving services including a hearing aid, a tutor, and a speech therapist
at her school. Her parents also wanted the school to provide her with a sign language interpreter
but the school district denied her request. When the case went before the Supreme Court they
ruled that the school district had in fact provided Amy with access to a free public education with
access to specialized instruction and related services that provided an educational benefit to her;
however, they were not obligated to provide her with full services but they were required to
provide her with access sufficient access to resources for disabled children. Since the school was
already providing her with adequate services, they were thus not required to provide Amy with a
sign language interpreter as well. This court case relates to Jonathan because it defines what a
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free and appropriate education would be and what services a school is required to provide a
student.
In McLaughlin v. Holt Schools Board of Education, the Sixth Circuit Court of Appeals
ruled that a student could be placed at a school other than their zoned school if that school
offered the program that the student needed. In this particular case Emma McLaughlin was a
kindergarten student with an IEP. During the IEP meeting the school and her parents disagreed
about whether she should be placed in a categorical classroom or a resource classroom. Her
parents felt that a resource class would be sufficient for their daughter while the district believed
that she needed to be in a categorical classroom. The school did not have the appropriate
categorical class that Emma needed so she would have to go to a school several miles away from
her house where they provided the necessary class. The parents did not agree with the school’s
decision and ended up suing them. The Supreme Court ruled that under IDEA the student is to
be placed in the least restrictive environment possible and that a student with an IEP must be
placed at their zoned school unless they do not have the categorical class; if the school does not
have the categorical class then the student will attended the next closest school that has the
necessary class. The Supreme Court has stated that since the school had determined that Emma
needed to be placed in a categorical classroom, it was acceptable to place her at a school with the
appropriate classes. This would relate to our case about Jonathan because if the high school that
he is attempting to enroll at doesn’t have the appropriate services then he should be able to enroll
at the next closest school that could provide for his needs.
Pennsylvania was a court case that helped to set the precedent for students with disabilities to
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attend public schools. In this case PARC along with the parents of several disabled students,
who had been denied a free public education by the state of Pennsylvania, sued the
Commonwealth of Pennsylvania for a law that had been used to keep students with disabilities
out of the public school system. The plaintiffs argued that all students, including those with
disabilities, would benefit from a free public education and that if they did not have access to this
education then their development would be negatively impacted. They also reasoned that
although these disabled children may not learn and develop the same way that other students
may, they would still benefit from these services. The U.S. District Court ruled in favor of the
plaintiffs, stating that denying any student the right to a free public education was
unconstitutional. They furthered their ruling to also state that the state of Pennsylvania was
responsible for providing a free public education to all students and also that students with
disabilities were to receive the same level of education as those students without disabilities.
This court case’s precedent would indicate that in the case regarding Jonathan, the school district
is not allowed to deny a free public education to him regardless of his disabilities.
Cedar Rapids Community School District v. Garret F. set the precedent for whether
providing a one-on-one nurse during school was considered a related service under IDEA. In
this particular case Garrett, a fifth grade student, was a quadriplegic who was also dependent on
a ventilator; this meant that he needed a one-on-one nurse nearby to help with certain physical
needs while he was in school. His parents provided a nurse for him up until fifth grade when
they requested that the school district take on the financial responsibility of hiring a licensed
nurse full time. The district denied their request and ultimately the Supreme Court ruled in favor
of the parents. Their reasoning was that schools were required under IDEA to provide related
services that were deemed necessary for the student to benefit from special education. A
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previous court case, Irving Independent School District v. Tatro, defined which services were
considered relative and which were considered medical. In that case medical services were any
services that were required to be done under the care of a physician. The Supreme Court ruled
that since Garrett required only a nurse, it fell under related services and therefore the school was
responsible for providing it. In our case Jonathan is also a quadriplegic student whose needs can
be met through the care of a nurse which would be considered a related service and thus the
I believe that ultimately Principal Debbie Young’s decision to not let the student enroll at
her high school is not defensible. In Board of Education of the Hendrick Hudson Central School
District v. Rowley, the Supreme Court ruled that a school must provide a free and appropriate
education. By not allowing to Jonathan to enroll, the principal is making no efforts to provide
this student even minimal services and is thus violating IDEA. The decision in McLaughlin v.
Holt Schools Board of Education, allows a student to attend another school that could meet their
needs, but if this high school is refusing to meet Jonathan’s needs then other high schools would
have the same right to do the same thing and thus Jonathan would never be allowed to attend any
Pennsylvania set the precedent that all students, regardless of disabilities, is entitled to a free
public education; this means that Jonathan would be entitled to a free public education at this
high school. The most important and relevant case for Jonathan is Cedar Rapids Community
School District v. Garret F. This case used former precedent from cases such as Irving
Independent School District v. Tatro that had defined the difference between related and medical
services. Schools are required to provide related services but not medical services; medical
services are defined as one’s that require a physician to perform them while related services can
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be performed by a nurse. Since Jonathan only requires a nurse to assist him, this would fall
under a related service that the school would be required to provide for Brandon. Since Brandon
is entitled to a free and public education and is eligible for related services such as a nurse,
References
Cedar Rapids Community School Dist. v. Garret F., 526 U.S. 66, 119 S. Ct. 992, 143 L. Ed. 2d
154 (1999).
Hendrick Hudson Dist. Bd. of Ed. v. Rowley, 458 U.S. 176, 102 S. Ct. 3034, 73 L. Ed. 2d 690
(1982).
McLaughlin v. Hold Public Schools Bd. of Educ., 320 F.3d 663 (6th Cir. 2003).
Pennsylvania Ass'n, Ret'd Child. v. Commonwealth of Pa., 343 F. Supp. 279 (E.D. Pa. 1972).