D.E v. Cent. Dauphin Sch. Dist.

D.E., now 23 years old, was a minor diagnosed with a learning disability and enrolled in school in the Central Dauphin School District. His parents claimed that while D.E. was enrolled in Central Dauphin he was deprived of a free appropriate public education (FAPE), in violation of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400, and that he was discriminated against based upon his disabilities, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12132, and the Rehabilitation Act of 1973 (RA), 29 U.S.C. 794. The district court dismissed the IDEA claims for failure to exhaust administrative remedies, and later granted summary judgment in Central Dauphin's favor as to the ADA and RA claims. The Third Circuit affirmed as to the ADA and RA claims, but reversed dismissal of the IDEA claim. Individuals seeking to enforce a favorable decision obtained at the administrative level are "aggrieved" for purposes of the IDEA and may properly pursue such claims in court. The court stated: "we encourage the District Court to consider any form of compensatory education proposed" in a manner consistent with the IDEA and Third Circuit precedent. View "D.E v. Cent. Dauphin Sch. Dist." on Justia Law