Cedar Rapids Community School District v. Garret F. (1999)

By Layna Grassi 

Overview  

Cedar Rapids Community School District v. Garret F. (1999) is a Supreme Court case in which  the plaintiff, a school district, argued that it was not required to provide continuous nursing  services to a student with a disability during school hours. The defendant, Garret F., argued that  the school district was required to provide these services under the Individuals with Disabilities  Education Act (IDEA). The primary issue in this case was whether the IDEA requires public  school districts to provide and pay for nursing services for students with disabilities when those  services are necessary for the student to attend school.  

Summary  

Garret F. became paralyzed from the neck down after a motorcycle accident at age four, but his  mental capacities were unaffected, and he was able to speak, operate a motorized wheelchair, and  use a computer through adaptive devices [1]. He attended regular classes in the Cedar Rapids Community School District and performed  successfully academically, but as a wheelchair user dependent on a ventilator, he needed a  responsible individual nearby to attend to his physical needs throughout the school day [1]. This included assistance with urinary bladder catheterization, suctioning of his tracheotomy tube,  repositioning, and monitoring in case of a ventilator malfunction. During his early school years,  Garret’s family covered the cost of this care themselves, first through a relative and later by hiring a licensed practical nurse. In 1993, Garret’s mother asked the district to accept financial  responsibility for these services going forward, but the district refused, maintaining that it was  not legally obligated to provide one-on-one nursing care.  

Garret’s mother requested a due process hearing before an Administrative Law Judge (ALJ) in  the Iowa Department of Education. The ALJ concluded that the IDEA required the district to  provide “school health services,” delivered by a qualified school nurse or other qualified person,  but did not require it to provide “medical services” which are limited to services performed by a  physician [1]. The ALJ found that most of the health-related services Garret needed were  already being provided to other students in the district, and that the district did not contend any  of the disputed services required a licensed physicians training [2]. The Federal District Court upheld this ruling, and the Eighth Circuit  Court of Appeals affirmed, despite the district's arguments that such extensive one-on-one care  was too costly and too involved to be considered anything other than medical in nature [1]. In reaching this conclusion, the Eighth Circuit applied a two-step test drawn from the Court’s  earlier decision in Irving Independent School District v. Tatro (1984): first, whether the requested  services qualify as “supportive services” necessary for the child to attend school. And second,  whether the services are not excluded as “medical services.” The Eighth Circuit found both steps were in Garret’s favor, reasoning that Tatro established a bright line rule under which only  services that must be performed by a physician fall under the medical exclusion.  

Before the Supreme Court, the district challenged only the second step of this analysis, asking  the Court to replace Tatro’s bright line test with a multifactor test weighing consideration such as  whether the requested care was continuous or intermittent, whether existing school staff could  provide it, its cost, and the potential consequences of inadequate care. The Court rejected this proposal, finding no support for it in either the statutory text or the regulation upheld in Tatro,  and noting that the district could not explain why factors like cost or continuity would make a  service anymore “medical” in nature [2].

In a 7-2 decision authored by Justice John Paul Stevens, the Court held that school districts  receiving federal funding under the IDEA must provide services that are necessary to keep a  student with disabilities in school and have the ability to access the same educational  opportunities as other students [1]. The Court acknowledged that the nature and cost of  providing such services does not determine whether a district must fund them but noted that  potential financial burdens may still inform how such requirements are applied more broadly. In  Garret’s case specifically, the benefits of providing him with the needed care outweighed the  burdens to the district [1]. Justice Clarence Thomas, joined by Justice Anthony Kennedy,  argued Tatro had been wrongly decided because it focused on who provided a service rather  than the nature of the service itself, and contended that the IDEA’s origins as spending-power  legislation required the Court to interpret the statute narrowly rather than impose unanticipated  financial burdens on the states [2]. 

Impact  

This decision reinforced the bright-line test that was first established in Irving Independent  School District v. Tatro (1984), confirming that only services requiring a licensed physician fall  under the IDEA’s “medical services” exclusion, regardless of how costly or continuous the  required care may be [2]. By declining to  adopt the school district's proposed multifactor test, the Court foreclosed the ability of school  districts to limit their obligations under IDEA based on the cost or intensity of a student's needs, holding instead that such policy considerations were for Congress, not the courts, to weigh [2]. The ruling established that if the  services in question are “related” to keeping a student with a disability in school and able to  access the same educational opportunities as other students, IDEA-funded school districts must  provide them, even when doing so requires hiring additional staff [1]. As a result, Cedar  Rapids Community School District v. Garret F. set a broad precedent that a student’s need for  extensive, one-on-one health related support doesn’t diminish a school district’s obligation to  provide it, so long as the services can be performed by someone other than a physician.  

Court Documents  

Cedar Rapids Community School Dist. v. Garret F., 526 U.S. 66 (1999) 

Citations

[1] "Cedar Rapids Community School Dist. v. Garret F." Oyez, www.oyez.org/cases/1998/96-1793.  Accessed 3 Sep. 2026. 

[2] Cedar Rapids Community School Dist. v. Garret F., 526 U.S. 66 (1999), JUSTIA U.S. Supreme  Court, 3 Mar., 1999, Cedar Rapids Community School Dist. v. Garret F. | 526 U.S. 66 (1999) |  Justia U.S. Supreme Court Center