IDEA Standard: Reasonable Does Not Mean Perfect
S.C., Through His Parent Helen C. v. Oxford Area School District: Reasonable Does Not Mean Perfect
The Third Circuit Court of Appeals recently issued a decision in favor of Oxford Area School District making it clear that the standard under the Individuals with Disabilities Education Act (IDEA) for providing a free appropriate public education (FAPE) does not require perfection.
In this case, in 9th grade, the student, S.C., missed well over a hundred class periods and failed five classes, but he made progress on his IEP goals and advanced to the next grade by taking summer classes. S.C. performed better in 10th grade and increased his GPA from 0.97 to 2.04. In 11th grade, S.C. had uneven academic progress; nonetheless, he raised his GPA to 2.19. However, his absences from classes increased again and his parent relayed to the school a doctor’s note reporting S.C. had anxiety about his 11th grade English class. Each year, S.C. advanced from grade to grade and increased his GPA, all while missing many of his classes. Each year, the school district reconvened his IEP team and updated his IEP as deemed appropriate at the time based upon the information available.
The panel of judges from the Third Circuit ruling on this case rejected the parent’s argument that something more was required by the United States Supreme Court’s 2017 ruling in Endrew F. v. Douglas County School District. Rather, in S.C. v. Oxford Area School District, the court firmly makes clear that the IDEA requires nothing more of public schools than offering a disabled student “an educational program reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.”
In S.C. v. Oxford Area School District, the court states:
- A school district must take steps that are reasonably calculated to enable a student to make appropriate academic progress in light of his circumstances.
- As long as the district does so, it is not liable just because a student does not progress as quickly as his peers.
The Third Circuit rejected all of the parent’s arguments, stating “reasonable does not mean perfect.” The opinion further explains that a student’s IEP “need not and cannot guarantee a student’s academic progress” and that slow progress does not prove that a program was deficient.
The court also stated how giving oral prompts, preferential seating near the front of the classroom, extra time on assignments and an academic support class to help with organization and focus were adequate measures to address S.C.’s anxiety. The court further rejected any argument that imposed a duty on the school district to address S.C.’s anxiety before the school was made aware of it from the parent.
In summary, the court noted it was unfortunate that S.C. did not progress as far or as fast as his parent would have hoped, but the court found that the school district met all of its legal obligations. Click here to read the court’s decision.
Jennifer Donaldson represented Oxford Area School District in this matter. Eastburn and Gray’s Education and School Law practice group routinely advises clients regarding IDEA mandates and all school-related legal issues. To learn more about the firm’s Education Law group, please visit: https://www.eastburngray.com/practice-areas/education-school-law/.