Mills v. Board of Education of District of Colombia (1972)
- Sam Shepherd
- May 19, 2024
- 3 min read
Updated: Oct 27, 2024
By Stephanie Aguilar
Overview
In Mills v. Board of Education of the District of Columbia, the parents of seven children with disabilities sued the District of Columbia for excluding and/or denying them access to education. The court ruled that children with disabilities have a right to public education and cannot be denied based on insufficient funds. This ruling led to many reforms regarding special education.
Summary
The District of Columbia had failed to provide thousands of children with disabilities suitable education. So, in 1972, Peter Mills, one of the seven Plaintiffs, sued the District of Columbia (Defendant) for being excluded from school due to his disabilities. Mills was not given a hearing or review of his status after being excluded and had not provided him with the reenrollment/enrollment in public or private schools. The other six Plaintiff children faced similar situations, where they were either excluded and/or denied access to education due to their disabilities.
By law, the Board of Education is obligated to provide every child in the District of Columbia, including those with disabilities, a publicly supported education. In addition, they are required to provide a fair hearing and regular reviews, which they failed to do when deciding to exclude or deny the Plaintiffs access to education.
In this case, the Plaintiffs argued that being denied public funded education without a hearing or periodic review violated the Due Process clause and cited multiple precedent cases such as Brown v. Board of Education (1954) and Hobson v. Hansen (1967). The Defendants argued that there was insufficient fund to provide education to children with disabilities with special programs and services within the District of Columbia. The Court was not persuaded by the Defenses arguments, and emphasized that even if there are financial constraints, the available funding should be spent fairly that ensures that no child is excluded from receiving public education suitable for their needs.
In the Judgement, the Court ruled in favor of the Plaintiffs and ordered that no child should be excluded from public schools unless there is an alternative education option suitable for the child and if they are given a fair “hearing and periodic review of the child’s status, progress, and the adequacy of any educational alternative” (Mills v. Board of Education of District of Columbia, 1972). Every child, regardless of disabilities, will be provided with a free and suitable education. Announcements and notices will be placed in multiple news papers to inform residents of the children’s right to suitable public education and the procedures of enrollment. The Court order established procedures for conducting hearings and disciplinary actions for the Plaintiff class. Additionally, it included many other provisions such as identifying those of the Plaintiff class, and notifying the children who were excluded or denied public education in the 1971-1972 school year.
Impact
Before the Mills v. Board of Education case, children with disabilities often faced exclusion from schools, depriving them of access to free public education. This exclusion limited opportunities for these children to excel academically and socially. However, this case had a huge impact on special education, transforming the education system for children with disabilities. Mills v. Board of Education challenged common biases and set a precedent for protecting the educational rights of children with disabilities. This ruling not only established that all children, including those with disabilities, are entitled to receive free appropriate public education (FAPE) but it also created a more inclusive educational environment.
Mills v. Board of Education laid the groundwork for many legislative reforms, including the adoption of the Individuals with Disabilities Education Act (IDEA), which was built on the principles of FAPE. IDEA ensures that children with disabilities would receive a free appropriate public education tailored to their needs.
After Mills v. Board of Education, there was a notable transformation within the education system. This case served as a legal precedent, shaping the development of special education law and policy within the United States.
Citation
Mills v. Board of Education of District of Columbia, 348 F. Supp. 866 (D.D.C. 1972), https://scholar.google.com/scholar_case?case=16525133616378659396&q=Mills+v.+Board+of+Education+of+Dist.+of+Columbia,+348+F.+Supp.+866+(D.D.C.+1972)&hl=en&as_sdt=803. (Accessed 12 June 2024).
Court Documents
To read the full Memorandum Opinion, Judgement, and Decree, click here:
To read other court orders related to the Mills v. Board of Education case, click here:
To read the Individuals with Disabilities Education Act (IDEA), click here:
