Boone v. Rankin County
Boone
Court
Fifth Circuit Court of Appeals
Decided
June 18, 2025
Jurisdiction
F
Importance
47%
Case Summary
Case: 23-60333 Document: 140-1 Page: 1 Date Filed: 06/18/2025 United States Court of Appeals for the Fifth Circuit United States Court of Appeals ____________ Fifth Circuit FILED No. 23-60333 June 18, 2025 ____________ Lyle W. Cayce Clerk Olivia Boone, as next friend K.A., A Minor, Plaintiff—Appellant/Cross-Appellee, versus Rankin County Public School District, Defendant—Appellee/Cross-Appellant. ______________________________ Appeal from the United States District Court for the Southern District of Mississippi USDC No. 3:22-CV-46 ______________________________ Before Stewart, Clement, and Willett, Circuit Judges. Carl E. Stewart, Circuit Judge: Olivia Boone brings this case under the Individuals with Disabilities Education Act (IDEA) on behalf of her autistic son, K.A. In 2020, K.A.’s school district notified Boone that he would be moved to a new program at a different school despite her objections to that plan. Boone filed a complaint with the Mississippi Department of Education alleging that the school district violated the IDEA by unilaterally making that placement decision. A hearing officer found that the school district violated the IDEA and ordered relief for Boone but denied her request for compensatory educational Case: 23-60333 Document: 140-1 Page: 2 Date Filed: 06/18/2025 No. 23-60333 services. Boone filed this suit to appeal the hearing officer’s denial of compensatory educational services and to seek attorneys’ fees. The district court affirmed the hearing officer’s decision and held that Boone was entitled to attorneys’ fees. Boone timely appealed to this court, and the school district timely cross-appealed. For the following reasons, we AFFIRM. I. A. Statutory Background The IDEA is an “ambitious” statute. Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. Dist. RE-1, 580 U.S. 386, 399–400 (2017). It “offers States federal funds to assist in educating children with disabilities.” Id. at 390 (citing 20 U.S.C. § 1400 et seq.). In exchange, States must “provide a free appropriate public education . . . to all eligible children.” Id. (citing 20 U.S.C. § 1412(a)(1)). And States must provide special education and related services to children with disabilities “in conformity with the [child’s] individualized education program.” Id. at 390–91 (quoting 20 U.S.C. § 1401(9)(D)). An individualized education program is a plan prepared by a child’s teachers, school officials, and parents that must be drafted in compliance with a detailed set of procedures. See id. at 391. Those procedures “emphasize collaboration among parents and educators and require careful consideration of the child’s individual circumstances.” Id. (citing 20 U.S.C. § 1414). A child’s individualized education program ensures that special education and related services are “tailored to the unique needs” of that particular child. See Bd. of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176, 181 (1982). The IDEA affords a “basic floor of opportunity” which consists of access to specialized instruction and related services which are “individually designed to provide educational benefit to the [disabled] child.” Id. at 200–01. 2 Case: 23-60333 Document: 140-1 Page: 3 Date Filed: 06/18/2025 No. 23-60333 In the event that parents and educators disagree about what a child’s individualized education program should contain, they may resolve their differences informally, through a meeting or mediation. 20 U.S.C. § 1415(e), (f)(1)(B)(i). If those measures prove fruitless, the parties may proceed to a “due process hearing” before a state or local educational agency. § 1415(f)(1)(A), (g). And at the conclusion of that administrative process, aggrieved parties may seek redress in court. § 1415(i)(2)(A). B. Factual Background K.A. is a teenage male with severe autism. Since kindergarten, he has received special education through the Rankin County School District (the “School District”). A comprehensive evaluation in early 2014 determined that K.A. was eligible for an individualized education program. Since then, K.A. has struggled academically an
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Status
Decided
Date Decided
June 18, 2025
Jurisdiction
F
Court Type
appellate
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Case: 23-60333 Document: 140-1 Page: 1 Date Filed: 06/18/2025
United States Court of Appeals
for the Fifth Circuit United States Court of Appeals
____________ Fifth Circuit
FILED
No. 23-60333 June 18, 2025
____________
Lyle W. Cayce
Clerk
Olivia Boone, as next friend K.A., A Minor,
Plaintiff—Appellant/Cross-Appellee,
versus
Rankin County Public School District,
Defendant—Appellee/Cross-Appellant.
______________________________
Appeal from the United States District Court
for the Southern District of Mississippi
USDC No. 3:22-CV-46
______________________________
Before Stewart, Clement, and Willett, Circuit Judges. Carl E. Stewart, Circuit Judge: Olivia Boone brings this case under the Individuals with Disabilities Education Act (IDEA) on behalf of her autistic son, K.A. In 2020, K.A.’s school district notified Boone that he would be moved to a new program at a different school despite her objections to that plan. Boone filed a complaint with the Mississippi Department of Education alleging that the school district violated the IDEA by unilaterally making that placement decision. A hearing officer found that the school district violated the IDEA and ordered relief for Boone but denied her request for compensatory educational Case: 23-60333 Document: 140-1 Page: 2 Date Filed: 06/18/2025
No. 23-60333
services. Boone filed this suit to appeal the hearing officer’s denial of compensatory educational services and to seek attorneys’ fees. The district court affirmed the hearing officer’s decision and held that Boone was entitled to attorneys’ fees. Boone timely appealed to this court, and the school district timely cross-appealed. For the following reasons, we AFFIRM. I. A. Statutory Background The IDEA is an “ambitious” statute. Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. Dist. RE-1, 580 U.S. 386, 399–400 (2017). It “offers States federal funds to assist in educating children with disabilities.” Id. at 390 (citing 20 U.S.C. § 1400 et seq.). In exchange, States must “provide a free appropriate public education . . . to all eligible children.” Id. (citing 20 U.S.C. § 1412(a)(1)). And States must provide special education and related services to children with disabilities “in conformity with the [child’s] individualized education program.” Id. at 390–91 (quoting 20 U.S.C. § 1401(9)(D)). An individualized education program is a plan prepared by a child’s teachers, school officials, and parents that must be drafted in compliance with a detailed set of procedures. See id. at 391. Those procedures “emphasize collaboration among parents and educators and require careful consideration of the child’s individual circumstances.” Id. (citing 20 U.S.C. § 1414). A child’s individualized education program ensures that special education and related services are “tailored to the unique needs” of that particular child. See Bd. of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176, 181 (1982). The IDEA affords a “basic floor of opportunity” which consists of access to specialized instruction and related services which are “individually designed to provide educational benefit to the [disabled] child.” Id. at 200–01.
2
Case: 23-60333 Document: 140-1 Page: 3 Date Filed: 06/18/2025
No. 23-60333
In the event that parents and educators disagree about what a child’s
individualized education program should contain, they may resolve their differences informally, through a meeting or mediation. 20 U.S.C. § 1415(e), (f)(1)(B)(i). If those measures prove fruitless, the parties may proceed to a “due process hearing” before a state or local educational agency. § 1415(f)(1)(A), (g). And at the conclusion of that administrative process, aggrieved parties may seek redress in court. § 1415(i)(2)(A). B. Factual Background K.A. is a teenage male with severe autism. Since kindergarten, he has received special education through the Rankin County School District (the “School District”). A comprehensive evaluation in early 2014 determined that K.A. was eligible for an individualized education program. Since then, K.A. has struggled academically an
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Status
Decided
Date Decided
June 18, 2025
Jurisdiction
F
Court Type
appellate
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Additional information
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