Schaffer v. Weast, 546 U.S. 49 (2005)
Primary Holding
The burden of persuasion in an impartial due process hearing under the Individuals with Disabilities Education Act (IDEA) lies with the party seeking relief.
In the case of Schaffer v. Weast, the Supreme Court decided that when parents challenge their child's special education plan, they are the ones who need to prove their case in a hearing. This is important because it sets a clear rule about who has the responsibility to show that changes are needed in a child's education plan under the Individuals with Disabilities Education Act (IDEA). This ruling helps protect consumers, particularly parents of children with disabilities, by clarifying their role in disputes over educational services. If you're in a situation where you believe your child's education plan isn't adequate, this case reminds you that you'll need to gather evidence to support your claims during any hearings.
AI-generated plain-language summary to help you understand this case
In Schaffer v. Weast, the dispute arose from the educational placement of Brian Schaffer, a minor with disabilities, whose parents, Jocelyn and Martin Schaffer, sought to challenge the individualized education program (IEP) developed by the Montgomery County Public Schools. The Schaffers believed that the IEP was inappropriate and requested an impartial due process hearing under the Individuals with Disabilities Education Act (IDEA). This Act mandates that school districts provide a free appropriate public education to children with disabilities and outlines the process for parents to contest the adequacy of their child's IEP. The procedural history of the case began when the Schaffers initiated a due process hearing to contest the IEP. The hearing officer ruled in favor of the school district, determining that the IEP was appropriate. The Schaffers subsequently appealed this decision to the U.S. District Court for the District of Maryland, which upheld the hearing officer's ruling. The case was then appealed to the U.S. Court of Appeals for the Fourth Circuit, which also affirmed the lower court's decision. The Schaffers petitioned for a writ of certiorari, leading to the Supreme Court's review of the case. The relevant background context includes the IDEA's framework, which was designed to ensure that children with disabilities receive appropriate educational services. The Act, however, does not specify which party bears the burden of persuasion in due process hearings. This ambiguity became a central issue in the case, as the Supreme Court ultimately ruled that the burden of persuasion lies with the party seeking relief, which in this instance was the Schaffers. This ruling clarified the procedural expectations for future disputes under IDEA.
Whether the burden of persuasion in an impartial due process hearing under the Individuals with Disabilities Education Act (IDEA) lies with the party seeking relief.
The judgment is reversed and remanded.
- Court
- Supreme Court
- Decision Date
- October 5, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Board of Ed. of City School Dist. of New York v. Tom F., 552 U.S. 1 (2007)
Consumer LostThe Supreme Court affirmed the lower court's decision by an equally divided Court, indicating that the ruling of the Second Circuit stands without establishing a new legal principle or rule.
Winkelman v. Parma City School Dist., 550 U.S. 516 (2007)
Consumer WonParents of a child with disabilities have the right to represent themselves and their child in court proceedings under the Individuals with Disabilities Education Act (IDEA), even if they are not licensed attorneys.
Arlington Central School Dist. Bd. of Ed. v. Murphy, 548 U.S. 291 (2006)
Consumer LostThe Individuals with Disabilities Education Act (IDEA) does not authorize prevailing parents to recover attorneys' fees for expert services rendered in actions brought under the Act.
Zuni Public School Dist. No. 89 v. Department of Education, 550 U.S. 81 (2007)
Consumer LostThe statutory language of the federal Impact Aid Act permits the Secretary of Education to determine which school districts to "disregard" when calculating disparities in per-pupil expenditures by considering both the size of the district's expenditures and the number of pupils in the district.