Blackmon v. Springfield R-XII School District (1999)

By Abigail Lentine 

Overview

Blackmon v. Springfield R-XII School District is a federal education law case that examines when a school district should, under the Individuals with Disabilities Education Act (IDEA), evaluate a student for special education services [1]. The case centers on Grace Blackmon, when her parents argued that the district failed to identify her as a student with a disability. After removing Grace from public school and placing her in a private program, her parents sued for reimbursement, claiming the district denied her a free appropriate public education (FAPE). The court reviewed whether the district had sufficient reason to suspect a disability and, therefore, a legal obligation to evaluate Grace under IDEA [1].

Summary

Grace Blackmon was a student in the Springfield R-XII School District with a documented history of severe developmental disabilities, including a diagnosed brain injury and behaviors associated with autism [1][2]. The district evaluated Grace under IDEA and developed an individualized education program (IEP) to address her needs. However, Grace continued to experience significant academic and behavioral difficulties while enrolled in the district’s schools. She exhibited disruptive behaviors that limited her ability to function effectively in a classroom setting. Although the district attempted to provide services through the proposed IEP and general education supports, Grace’s parents became concerned that the placement and services were inappropriate. They believed the district’s proposed program failed to provide Grace with a free, appropriate public education.

As Grace’s difficulties continued, her parents became increasingly concerned that the district was not addressing these issues properly. Grace's parents observed ongoing behavioral and academic difficulties, which led them to believe she required additional attention beyond the current IEP structure. They decided to remove her from the Springfield R-XII School District and enroll her in a private home-based program focused on behavioral support rather than regular classes. After making this change, they requested reimbursement from the school district, asserting that the private program was necessary because the district failed to properly provide her the support she needed under IDEA [2].

Under the IDEA, school districts are legally responsible to evaluate a student if they have reasonable evidence to suspect a disability[1]. This is because IDEA requires a FAPE, which Grace’s parents argued she did not receive through the district’s proposed IEP given after evaluation. Grace's parents stated that private placement became necessary for FAPE and, therefore, qualified for reimbursement under IDEA. The district argued that Grace's problems were primarily due to disciplinary issues, not a disability.  The key issue in the case was whether the district’s proposed IEP appropriately met Grace’s educational needs required by IDEA [1].

The United States Court of Appeals for the Eighth Circuit found that the Springfield R-XII School District did not violate IDEA because the district’s proposed IEP was reasonably designed to provide Grace with a FAPE [1]. Due to the district’s IEP meeting IDEA’s legal standard, the court found that Grace was not denied FAPE. As a result, Grace’s parents were not entitled to reimbursement for the private placement [1].

Impact

Blackmon v. Springfield R-XII School District shows that a school district’s duty to evaluate a student under IDEA is limited. This case makes it clear that schools are not required to evaluate every student who struggles in class or has behavior problems. Instead, this case clarifies that evaluation is necessary only when there is evidence supporting a disability. The decision also reinforces that parents may receive reimbursement for private placement only when an IDEA violation has occurred. 

Court Documents 

[1] Blackmon v. Springfield R-XII School District, United States Court of Appeals for the Eighth Circuit (1999), https://scholar.google.com/scholar_case?case=4403789684768396278 

Citations

[2] Blackmon v. Springfield R-XII School District, case brief, Studicata, https://www.studicata.com/case-briefs/case/blackmon-v-springfield-r-xii-school-dist