Irving Independent School District v. Tatro (1984)
- Sam Shepherd
- Oct 26, 2024
- 4 min read
By: Nicole Tursellino
Overview
Irving Independent School District v. Tatro, 468 U.S. 883 (1984) helped in the process of making clear how public schools that were federally funded should provide services to students with disabilities and clarified how these institutions should be interpreting the Education for All Handicapped Children Act (EHA). This case allowed for the interpretation of what was considered a ‘related service’ and what was considered a ‘medical service’ in the court of law. The case found in a unanimous decision by Chief Justice Warren Burger that clean intermittent catheterization (CIC) was considered a ‘related service’ but not a ‘medical service’ under the terms of the Education for All Handicapped Children Act. This case brought to light not only key differences between the writings and interpretations of the EHA and the Rehabilitation Act, but also set a precedent for how public schools in the future were to proceed with assisting individuals with disabilities.
Summary
Amber Tatro was a child who possessed spina bifida, a condition that takes place when an individual's spine and spinal cord do not develop in a proper manner. As a result of this, Amber had suffered from a neurogenic bladder, which required a catheter that needed to be emptied once every four hours or so; for Amber, this method of catheterization was clean intermittent catheterization (CIC), but due to her young age, she needed assistance with this process. A physician need not be the individual that conducts CIC, and rather, it is something that can be taught to individuals who are willing to learn the process of tending to the catheter. As Amber approached the age of being able to attend school, Amber was to attend public schooling in the Irving Independent School District, a school district based in Irving, Texas. The school district, which followed the EHA accordingly, agreed to provide Amber with special education services, such as physical and occupational therapy; however, the school neglected to assist Amber with CIC services during the hours in which she was in school.
The Tatro family sued the school district, as well as the Texas State Board of Education, claiming that the school district was negligent in assisting their daughter Amber with CIC services. When the case entered District Court, the Tatro’s case was denied a preliminary injunction, as the court found that providing CIC services to a child did not count as a ‘related service’ to educational-based needs (which was required by EHA). However, the Fifth Circuit in the US Court of Appeals found that CIC was a ‘related service,’ where the case was once more moved back to the district court. The District Court upheld that CIC was not necessarily a ‘medical service’ as it was a service that could be performed by any layperson and need not a doctor/physician to assist in the procedure of cleaning the catheter
When the case entered the Supreme Court’s docket, the court was faced to interpret the meanings behind ‘related services’ and ‘medical services’ via the EHA's guidelines. In a unanimous decision produced by Chief Justice Warren Burger, the Court upheld that CIC services were ‘related services’ under the EHA but not a ‘medical service.’ Since ‘related service’ was interpreted to mean services that were to assist handicapped service with access to public education, and since Amber could not go to school without assistance with CIC, then it was ‘related’ to assisting her in getting the education she needed. However, it was not deemed to be a ‘medical service’ since it was not a service that needed to be undertaken by a licensed medical professional.
Impact
This case assisted in the process of interpreting the EHA and how it applies to public education for individuals that are handicapped. With the court clarifying how CIC in this instance was deemed a ‘related service’ but not a ‘medical service,’ it proved how ‘related services’ in the EHA were services required to be offered by public institutions if absence of those services would prevent a student from receiving an education. It also demonstrated that ‘related services’ applies to health-related services as well if those services do not require the medical attention and assistance of a physician. In doing this, it has ultimately shifted the way in which medical services can be administered and provided within federally funded public institutions. If individuals possess a disability that can be assisted in a medical manner by individuals that are not doctors, then the individual with the disability is entitled by means of EHA to receive the care in which they need.
Tatro has been used as a reference in a variety of Supreme Court cases that took place after its ruling, allowing for Tatro to be used as a precedent for interpreting medical services in public schools. For example, Tatro was referred to during Cedar Rapids Community School District v. Garret F., 526 U.S. 66 (1999), a case where a boy who became paralyzed required nurse services during the school day and needed a ventilator. The Court used the precedent set by Tatro to rule that this was a ‘related service’ and not a ‘medical service’ since no physician intervention was necessary, so the school was required to provide the care needed for this handicapped individual.
Additional Documents
To listen to the Oral Argument given on April 16, 1984, click here: https://www.oyez.org/cases/1983/83-558
To read the Opinions and Dissents of this case, click here: https://supreme.justia.com/cases/federal/us/468/883/#tab-opinion-1955731
To read the Education for All Handicapped Children Act of 1975, click here: https://www.gao.gov/assets/113316.pdf
To read a summarized version of the Education for All Handicapped Children Act of 1975, click here: https://www.gao.gov/products/113316
To learn more about clean intermittent catheterization (CIC), click here: https://www.rch.org.au/rchcpg/hospital_clinical_guideline_index/Teaching_and_supporting_Clean_Intermittent_Catheterisation_for_parents_and_children/#:~:text=Clean%20Intermittent%20Catheterisation%20(CIC)%3A,the%20urine%20has%20been%20drained.
To read more about the Rehabilitation Act, click here: https://askearn.org/page/the-rehabilitation-act-of-1973-rehab-act
To learn more about Cedar Rapids Community School District v. Garret F., 526 U.S. 66 (1999), click here: https://supreme.justia.com/cases/federal/us/526/66/#tab-opinion-1960494
Citations
Cedar Rapids Community School District v. Garret F., 526 U.S. 66 (1999)
Irving Independent School District v. Tatro, 468 U.S. 883 (1984)
“Irving Independent School District v. Tatro.” Oyez, 2019, www.oyez.org/cases/1983/83-558.
“Irving ISD v. Tatro, 468 U.S. 883 (1984).” Justia Law,
Powell, Lewis. Irving Independent School District v. Tatro. 1983,
U.S. Department of Education. “A History of the Individuals with Disabilities Education Act.”
Individuals with Disabilities Education Act, U.S. Department of Education, 16 Feb. 2024,
