December 1993, Vol. 7, No. 4 ~~~~Return to INDEX

An "Ounce of Prevention..." News

Information and Ideas from IPPSE for Practical Problem Solving in Special Education


HEARING OFFICER FINDS INCLUSIVE

SETTING INAPPROPRIATE

A Massachusetts hearing officer ordered placement of a student with behavioral characteristics of autism and/or a pervasive developmental disorder in a self-contained program located in a separate facility. Sudbury Pub Sch, 20 IDELR 948.

Parents of the seven year old student wanted continued placement in the regular education first grade classroom. The student's IEP called for placement in a regular education kindergarten for both the morning and afternoon sessions, with instructional modifications, a behavior management plan, and an individual full time aide. Special education services were provided during a mid-day break which focused on language and academic skills. School personnel observed, however, that the student exhibited frequent disruptive and dangerous behaviors to himself and others in a large group setting, including kicking, biting, and throwing objects. While acknowledging that the student's language skills had improved in his current placement, the district attributed the improvement to the one-to-one special education service. The district maintained that the student learned best in a one-to-one setting, or in a small group of developmentally similar children. The district's recommendation was that the student be placed in a small group, highly structured setting with a behavioral focus. The recommended placement required that the child be transported to another district where the nearest self-contained program was operating. There were no self contained programs for elementary grades in the student's resident district.

At a due process hearing, the hearing officer considered several placement options: the current general education placement in the student's resident district, an out of district private school placement offering intensive, therapeutic services and an out of district special education collaborative program in a public school which offered opportunities for mainstream classes and "reverse mainstreaming" where regular students joined the program for specific activities. The hearing officer ordered that, given the student's unique educational needs, the least restrictive, most appropriate environment was the out of district, special education program. In doing so, the hearing officer admonished the resident school district, citing its failure to offer students within its district "a continuum of alternative placements tailored to address special education needs in the least restrictive setting."

IMPLICATIONS:

With the movement in education towards full time inclusion, this case seems like an anomaly. It provides a good opportunity to again see the "tension" created when trying to implement IDEA's requirements of LRE and meeting students' needs in an inclusive setting. LRE requires options--from self-contained to inclusive programs--a continuum of programs from which the IEPC selects the least restrictive which still meets the student's individual needs. LRE also requires that children with disabilities are educated with nonhandicapped children to the maximum extent that is appropriate, considering that the student's needs are met. Here, despite the presence of a full time aide, extensive curricular modifications, and a behavioral management plan, the student's autistic behavior escalated in the larger group setting.

Is this case "precedent" for anything? No. Just like the much publicized inclusion decisions in Oberti and Holland, this case stands for nothing more than what program was deemed appropriate to meet the individual needs of this child. But, it should not go unnoticed that the hearing officer here paid great attention to the efforts and variety of techniques used by the district before it proposed a more restrictive placement. You will recall in Oberti, the district alleged it had tried educating the student in a general education setting but without success. The courts there found the "effort" in terms of support to the student and teacher almost lacking. See OP News, Aug. 1993, Vol. 6, #12 at p. 4.


TEACHER ORDERED TO PAY DAMAGES FOR FAILING TO COMPLY WITH IEP

A West Virginia jury ordered a high school teacher to pay $15,000 in compensatory and punitive damages plus litigation costs to a student with learning disabilities because the teacher refused to comply with the accommodation of oral testing, as required by the student's IEP. Doe v Withers, 20 IDELR 422.

A ninth grade student was diagnosed as having a learning disability in fourth grade and began receiving special education services. The student's IEP provided for oral testing for all subjects by a learning disabilities teacher in a resource room. When the student reached high school, all teachers except the student's history teacher complied with the oral testing accommodation. Despite repeated requests from the parents and a written directive from the special education coordinator to permit the oral testing, the teacher continued to administer written exams. The student failed the first semester of the history class, but passed the rest of his classes. As a result of his failing grade, the student was not allowed to participate in extracurricular activities. The teacher refused to meet with the student's parents to discuss his noncompliance. He also insulted and belittled the student in front of the rest of the history class.

During the second semester of the school year, the history teacher took a leave of absence to serve in the state legislature (proving once again that truth is stranger than fiction!). The substitute teacher complied with the oral testing modification and the student's grades "dramatically improved" in the class.

The parents took the issue of the first semester grade to a hearing. The hearing officer ordered the principal, superintendent, and the school board to administer an oral re-test covering the first semester history material. School officials were also ordered to provide any tutoring or reteaching of material to prepare the student for the test.

The parents then filed suit under 42 USC 1983, claiming that their son was deprived of his statutorily granted civil right to a free, appropriate, public education under IDEA and state law. The teacher, principal, superintendent, and the board of education were named as defendants. The judge subsequently relieved the school officials of liability, except for the teacher. The jury awarded the student and his parents $5,000 in compensatory damages, $10,000 in punitive damages and also the costs of litigation.

IMPLICATIONS:

This case provides a good answer to the question,"Who has a legal duty to implement a student's IEP?" As the judge and the hearing officer held in this case, all school personnel have this responsibility. The IEP is a legal document, enforceable under state and federal law. A district is well advised to provide inservices about the responsibilities of districts under IDEA to implement an IEP. Here, while the district apparently did understand that the services contained in the document must be provided since it "directed" the teacher to do so, it didn't follow through further.

Recalcitrant teachers who do not wish to accommodate students with disabilities sometimes cite their "academic freedom" to instruct and evaluate students as they choose. Teachers may believe that the student with disabilities is given an "unfair advantage" because of a modification. But teachers and administrators need to understand that, regardless of their beliefs, the services, modifications and accommodations required by an IEP (unless appealed) must be implemented.

This is the only case we know of where a teacher has been held liable for not implementing an IEP. Given these facts, however, it is amazing that the teacher's job status was not attacked by the district! Possibly the fact that the teacher was also a legislator was the reason no action was taken but significant is the party actually at fault was the only one held responsible for damages. But what an expensive and time consuming lesson for all!

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NEW YORK COURT EXCLUDES

NURSING CARE AT SCHOOL

A New York court held that special nursing care for a medically fragile student was an excludable medical service under IDEA and state special education law.

The parents of a student who was paralyzed from the neck down and required a ventilator to breathe requested a specially trained nurse to assist the student at school.

The court determined that a specialized nurse for the sole benefit of this student was not a related service but was more akin to "medical" services. Ellison v Board of Educ of Three Village Cent Sch Dist, 19 IDELR 1027.

IMPLICATIONS:

With regard to the extent of school health services a district is required to provide under IDEA, courts have generally applied the "rule of reasonableness." Services beyond the range of a school nurse's competence or intensive or continuous services are not required. However, intermittent services provided on a reasonable available basis (e.g., tracheostomy suctioning, tube feeding, etc.) are required. Here, the nursing care was continuous and solely for the benefit of one child.

Some key, fundamental steps must be taken when determining whether school health services are needed and if so what type, constant or intermittent (including who must provide them, e.g., nurse or trained aide):

1. Get complete medical information, including the nature of the health problem, interventions required, and training necessary to provide interventions. Remember that the information on the student must be obtained from a physician, not the parent. This is a medical not an educational decision.

2. Obtain medical authorization and arrange for the supervision required by the public health code.

3. Provide staff rendering the school health services with information and the authorization as well as the appropriate training required to provide the intervention.

Under Michigan's Tort Reform Act, district employees providing school health services within the scope of their employment are generally immune from liability unless "grossly negligent" (i.e., conduct so reckless that it demonstrates a substantial lack of concern for whether injury results). If the above steps are not taken, such as no or inappropriate training, this could be sufficient to constitute "gross negligence." On the other hand, if these steps are taken, any potential liability is very remote.

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ATTORNEY FEES AWARDED AFTER SETTLEMENT

AT PRE-HEARING CONFERENCE

A federal court in Indiana awarded attorney fees under IDEA where parents received the relief requested at a pre-hearing conference with a hearing officer. Dutko v Warrick County Sch Corp, 20 IDELR 807.

The parents requested an administrative hearing to challenge the educational placement of their son. The school district offered the services that the parents wanted at a pre-hearing conference and the parents accepted. The court held that the parents as the prevailing parties were entitled to attorney fees for work performed prior to the holding of an administrative hearing.

IMPLICATIONS:

When and how to conclude an IEP can have critical implications regarding an award of attorney's fees. Once an IEP ends, attorney's fees can be awarded if the parent is the "prevailing party" well before a hearing occurs, as in the above situation. The district has control regarding the conclusion of an IEPC as long as it acts reasonably. Because the district may want to know all issues and disputes and the parent's position(s) concerning each, it might choose to adjourn the IEPC to give parents more time to identify the issues or what they want. With obviously litigious parents who are just unsure as to whether they agree to a particular IEP (or where the district might like to explore other options before heading to a hearing), the IEPC might be adjourned even over the vigorous objection of the parent provided the reason is legitimate and the delay is not unreasonable. Offering the parent additional time and thereby opportunities for resolving a dispute before the IEPC ends may avoid or mitigate the district's liability for attorney's fees. On the other hand, changes in position after the request for a due process hearing is made often provide a basis for reimbursement of the parent's attorney's fees (where moves made prior to the end of the IEPC typically will not). Candor in this regard with the parents might even motivate settlement if they understand their chances of obtaining attorney's fees will be diminished, should they choose not to cooperate by "running" to a hearing.Return to the TOP


OCR INVESTIGATION NEGATES PARENT'S CLAIM OF RETALIATION

OCR investigated a complaint that a school district retaliated against a parent who had filed a FAPE claim against the district with the state board of education. The parent alleged that the district reported suspected child abuse of his daughter to state authorities and also suspended the child from school as a result of his claim. OCR determined that the district had a legitimate basis for reporting the suspected abuse because the child told a school employee that her father hit her with a belt, causing bruises. OCR cited state law which requires teachers to make such reports. OCR also found that the child's suspension from school was a result of her behavior and was not retaliatory. Mill Creek Valley (KS) Unified Sch Dist, 20 IDELR 821.

IMPLICATIONS:

Don't let a litigious parent scare you off from reporting abuse when you have a legitimate belief that it is occurring, even if a possible claim of retaliation may result. In Michigan, school personnel, e.g., school nurse, social worker, administrator, counselor or teacher are under a statutory duty (MCL 722.623) to report child abuse or neglect if there is "reasonable cause to suspect" such harm. State law gives immunity from civil liability to school personnel acting in good faith when making a report or cooperating in an investigation. Failure to report, however, can create civil liability and possible criminal penalties if school personnel knowingly fail to act (MCL 722.633).

(See OCR INVESTIGATION, p. 6)

OCR INVESTIGATION (cont'd from p. 5)

With respect to school suspensions, it is important to remember the "rules" regarding suspension/expulsion of students with disabilities (e.g., suspension in excess of 10 days is considered a change in placement that cannot be instituted without the procedural requirements of IDEA), particularly those students who are identified as "emotionally impaired." This case also provides a good lesson regarding school policies and record-keeping. This district had a discipline policy which included progressive discipline. It also documented the incidents and how they were handled. OCR reviewed the policy and records to compare treatment of the complainant's daughter with another student in the general population who exhibited similar behavior and found that both students received the same punishment. This district followed standard discipline procedure and had the appropriate documentation to prove it.

In addition to having a discipline policy that recognizes the different "rules" for disciplining students with disabilities (e.g., the State Board's Position Statement on Suspension/Expulsion of Handicapped Students), districts must also avoid another trap. Just because two students (one of whom is disabled) have similar behaviors, a district should not automatically discipline the disabled student as they would a student without disabilities. Consideration should be given to whether the student with disabilities has a behavior management plan, if so, what it provides, and if not, given the student's behavioral history, should one be developed? Too often behavioral problems and attendant suspensions escalate to a crisis level before an appropriate behavior management plan (and training to implement it) are put in place.

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