Light v. Parkway C-2 School District (1994)
- 19 hours ago
- 3 min read
By: Kacie Matthews
Overview
Light v. Parkway C-2 School District court case shined exposure on Lauren Light, a 13 year old girl, who suffered from Spondyloepiphyseal Dysplasia (SED), Developmental Disabilities (DD), Behavioral Disorder (BD), and Megalocornea-Intellectual Disability (MMR), and had been diagnosed with Autism. Due to her disabilities, Lauren exhibited signs of aggression towards her own teachers, and classmates. Examples of her aggression included kicking, biting, hitting, throwing objects at others, and impulsive behaviors. After Light had struck and hit two of her classmates multiple times, the Parkway school district suspended her, and suggested Light be transitioned to a self-contained classroom, where there would be one teacher and one teacher’s assistant, both who were professionally trained to manage students with disorders, and those with Individualized Educational Programs (IEPs).
Summary
Lauren Light attended Parkway Central Middle School - a middle school located in the special school district of St. Louis County, Missouri that was devoted to teaching and educating children with special needs, alongside non-disabled students. Before the 1993-94 school year, Light was taught in a classroom alongside fifteen classmates, and two teachers. Teachers often complained that the necessary educational plan was never completed during the school year due to Light’s outbursts and aggressive tactics towards people around her. Nonetheless, Light was still being taught in a regular classroom. However, that all changed when the school decided to take action after Lauren stabbed a student in the stomach with a pencil, slapped students in the face, hit students directly, and bruised a non-disabled student. After the course of action, the school suspended her and decided to educate her within a “self-contained” classroom within the same school. The team, educators, and staff of Light’s middle school decided to create Light’s own Individualized Education Program (IEP). With the IEP, Light would be the only student, alongside two staff members: one teacher and one teacher’s assistant.
Parkway Central Middle School believed this would be the best tactic to allow other students to be safe, educated, and not distracted, as well as the best opportunity for Light to be taught the educational plan, without affecting a third party. Light was sent to the “self-contained” classroom. In order to meet with Light’s disability requirements, staff would regularly contact Light, Light would have classes sitting alongside her non-disabled peers, and Light would participate in outside activities and therapy, such as music therapy, which was only available for Light. After the “self-contained” classroom, Light was able to attend her regular classes at Parkway Central Middle School, however, her aggressive acts continued.
As a result, Light’s IEP team met again, and decided to take a new approach on how to better Light’s education, and others around her, and the overall result was a change in placement. Light’s parents objected to the “self-contained” classroom, and sought to proceed with the “stay-put” provision of IDEA. The “stay-put” provision involved not making any changes without her parent’s permission. The school respected their decision, until a chain of events happened during Light’s art class where she grabbed and tugged on her classmate’s hand, and with Light’s other hand, she hit the student three times on their head. Parkway Central Middle School called Light’s parents to discuss the event, however, neither parent attended the meeting, resulting in another suspension for Lauren Light. As a result of the suspension, her parents went to the district court to lift the suspension.
The Court sided with the school district, and claimed that schools may suspend and temporarily remove dangerous students even with parental objection. If the school made reasonable efforts and attempts to manage the student, and there has been no improvement, then there’s a large risk to students and staff around them. Even when parents support the “stay-put” provision, that is overridden when a student’s behavior is dangerous to themselves and others.
Impact
After the Court ruled in favor of the school district, it introduced a new procedure and standard for those with disabilities, and school districts. With the “stay-put” provision of IDEA, it is only valuable and followed when the given student is not dangerous, not harming others, and can continue their education. The “stay-put” provision cannot be used if there’s a threat to the safety of others due to that student.
Court Documents
Martin Light; Diane Light; Lauren Light, a Minor by Andthrough Martin and Diane Light, Her Next Friends;appellants; v. Parkway C-2 School District; Special School District of St.Louis County; Appellees, 41 F.3d 1223 (8th Cir. 1995), Justia
Citations
Light v. Parkway C-2 School District (1994), Law Resource, https://law.resource.org/pub/us/case/reporter/F3/041/41.F3d.1223.94-2333.html
Light v. Parkway C-2 School District (1994), Whitted Takiff,
