Florence District County Four v. Carter (1993)

By Nicole Tursellino

Overview

Florence County School Dist. Four v. Carter, 510 U.S. 7 (1993) presented the question of whether or not a court order could be implemented to provide the parents of a handicapped child with a financial reimbursement if the parent’s decide to withdraw their child from a publicly funded institution that is not completely complying with the Individuals with Disabilities Education Act (IDEA). In a unanimous decision under jurisdiction of the Supreme Court, Justice Sandra Day O’Connor delivered that the Court held that permitting specific circumstances, parents are to be reimbursed for private educational expenses if the parents chose to remove their child from a publicly funded institution due to the school’s lack of educational resources for disabled needs and noncompliance with IDEA. It also upheld that parents ultimately have the right to place their children in private institutions if the institution can provide an “appropriate” style of education for the handicapped individual in question.

Summary

Shannon Carter was a young girl who, while in public school, was diagnosed with a learning disability. While the public school met with Carter’s parents to establish an individualized education plan for Shannon, the plan that was constructed did not fully meet the needs of Shannon and did not fully comply with IDEA. With this, Shannon’s parents decided to remove her from public schooling and enrolled her in a private institution. When suing the Federal District Court, the Carter’s stated that the “free and appropriate education” clause guaranteed by IDEA had not fully been met, despite local and state officials claiming that the public school had, in fact, provided adequate accommodations for Shannon. The Carters then argued that since they now had to pay tuition for their daughter to be enrolled in schooling because their public school had not provided an adequate education, they should be reimbursed for the expenses they had already paid. 

When the case entered into the District Court, the court ruled that the Carter’s were to be reimbursed since the public school had not fully and completely followed the requirements of IDEA. The Fourth Circuit Court of Appeals agreed with this and ruled in the same manner. When the case presented itself on the Supreme Court’s docket, the Supreme Court found in a unanimous decision, with an opinion written by Justice Sandra Day O’Connor, that parents have a right to remove their children with disabilities from public schools if the school fails to provide proper services to the child in accordance with IDEA. Furthermore, the Court found that if the parents had thus decided to move their child to a private institution that did provide an appropriate and adequate education for the child in question, then the parents of that child were entitled to reimbursement via a court order. 

Impact

Florence County School Dist. Four v. Carter, 510 U.S. 7 (1993) allowed for the interpretation of IDEA in terms of education outside of publicly funded institutions. If publicly funded schools do not fully comply with the terms and conditions of IDEA, and a parent decides to unenroll their student from the public school and place them into a private school that does fully comply, then the parents can receive a full financial reimbursement per a court order. Not only did this case highlight the intersection of court orders, IDEA, and financial resources, but it also demonstrates the autonomy parents of handicapped students have when making decisions about the education of their child. In doing so, it also demonstrated the consequences of public schools not fully respecting the Free Appropriate Public Education (FAPE) act and highlighted the importance of following all aspects of the act. 

This case has also served as a precedent for other Supreme Court cases that have been ruled on. Forest Grove School District v. T.A., 557 U.S. 230 (2009), not only utilized Carter as a precedent, but expanded upon its ruling. This case furthered the process of re-funding individuals who had sent their child to private schools, regardless of whether the parent had previously sent their child to a public institution when the public schools in the individual district failed to provide the proper accommodations for the child in question. This not only demonstrates the ways in which Supreme Court cases can expand upon one another, but also highlights the importance and usage of precedent by the Court. Another case in which Carter was utilized as precedent was in Endrew F. v. Douglas County School District RE-1, 580 U.S. ___ (2017), where the Court examined Carter’s interpretation of FAPE in greater detail.

Additional Documents

To listen to the Oral Argument given on October 6, 1993, click here: https://www.oyez.org/cases/1993/91-1523

To read the Opinions and Dissents from this case, click here: https://supreme.justia.com/cases/federal/us/510/7/#tab-opinion-1959466

To learn more about the Individualized Educational Plan (IEP) is, click here: https://www.washington.edu/accesscomputing/what-difference-between-iep-and-504-plan#:~:text=IEP%20Defined,specialized%20instruction%20and%20related%20services.

To learn more about the Individuals with Disabilities Education Act (IDEA), click here: https://sites.ed.gov/idea/

To view the full case, click here: https://supreme.justia.com/cases/federal/us/510/7/#tab-opinion-1959467

For more information about Forest Grove School District v. T.A., 557 U.S. 230 (2009), click here: https://www.oyez.org/cases/2008/08-305

For more information about, Endrew F. v. Douglas County School District RE-1, 580 U.S. ___ (2017), click here: https://www.oyez.org/cases/2016/15-827

Citations

Endrew F. v. Douglas County School District RE-1, 580 U.S. ___ (2017)

Florence County School Dist. Four v. Carter, 510 U.S. 7 (1993)

“Florence County School Dist. Four v. Carter, 510 U.S. 7 (1993).” Justia Law, 2024, supreme.justia.com/cases/federal/us/510/7/#tab-opinion-1959466. Accessed 26 Oct. 2024.

“Florence County School District Four v. Carter.” Oyez, www.oyez.org/cases/1993/91-1523.

 Forest Grove School District v. T.A., 557 U.S. 230 (2009)

“Free Appropriate Public Education (FAPE).” U.S. Department of Education, 2024, www.ed.gov/laws-and-policy/civil-rights-laws/protecting-students/free-appropriate-public-education-fape.

Mantell, Paul. “Recent Developments: Florence County School Dist. Four v. Carter: Parents May Be Reimbursed for the Cost of a Private School When a Public School Fails to Provide an Adequate Education under the Individuals with Disabilities Education Act.” University of Baltimore Law Forum, vol. 24, 1994, scholarworks.law.ubalt.edu/cgi/viewcontent.cgi?article=1746&context=lf.

U.S. Department of Education. “Individuals with Disabilities Education Act.” IDEA, U.S. Department of Education, 2017, sites.ed.gov/idea/.

“What Is the Difference between an IEP and a 504.” Washington.edu, 2019, www.washington.edu/accesscomputing/what-difference-between-iep-and-504-plan.