Mr. I. v. Maine School Administrative District No. 55 (2007)

By Hannah Ngo

Overview

Mr. I. v. Maine School Administrative District No. 55 (2007) involves L.I., a student at Cornish

Elementary School who was denied an Individualized Education Program (IEP) despite facing significant emotional and developmental challenges. After a suicide attempt and a diagnosis of Asperger’s Syndrome (now recognized as Autism Spectrum Disorder), she was taken out of Cornish and enrolled in The Community School (TCS). Although the school district acknowledged her diagnoses, it denied her an IEP based on her academic performance. Following a due process hearing that upheld the district’s decision, her parents brought the case to federal court. The district court found that L.I. met the criteria for services under the Individuals with Disabilities Education Act and deemed L.I. eligible for an IEP.

Summary

In 2003, L.I. was a high-achieving fourth-grade student at Cornish Elementary School when she began showing signs of emotional distress. She experienced persistent sadness, anxiety, and difficulties in social interactions with peers. As her symptoms progressed, she was prescribed antidepressants and expressed a desire to either be homeschooled or attend TCS, a private school. Despite her concerns, she remained enrolled at Cornish for the 2003–2004 school year where her condition worsened. Her teacher observed a significant drop in classroom engagement and noticed self-inflicted cuts on her arms. To encourage her, the teacher and her mother created a contract that would allow L.I. to study topics of interest if she met her academic responsibilities, however L.I. refused to follow the plan. On October 1st, 2003, following a confrontation with her mother about the assignments, L.I. attempted suicide by ingesting a combination prescription and over-the-counter medications. Following the attempted suicide, her parents removed her from Cornish Elementary and arranged for neuropsychological testing with Dr. Ellen Popenoe, who suspected that L.I. met the criteria for Asperger’s Syndrome. The findings were shared with Jim McDevitt, the district’s Director of Special Services, who informed the family that the PET had convened and agreed L.I. wouldreceive ten hours of tutoring per week while additional assessments were conducted. Despite this decision, the district failed to provide the promised tutoring. Due to the lack of support and communication, Mrs. I began homeschooling her daughter.

On January 5, 2004, L.I. was officially enrolled at The Community School. In March, the PET

reconvened and acknowledged her diagnoses of Asperger’s Syndrome and adjustment disorder. However, the team did not reach a consensus on whether she qualified for special education services under the IDEA. The district argued that “her condition did not adversely affect her [education]” (Mr. I. v. Maine School Administrative District No. 55, 2007). A written notice was issued to formally deny IDEA services, and the district recommended evaluating L.I. under the Rehabilitation Act instead. In a subsequent meeting, the PET found her eligible for accommodations under that statute and proposed services such as social skills instruction, tutoring, and potential placement within a district school. Her parents, however, chose to continue L.I. ‘s education at The Community School and sought reimbursement through IDEA.

Mr. and Mrs. I requested a due process hearing, during which the hearing officer ruled in favor of the school district. Disagreeing with the outcome, the parents brought the case to district court. Although the magistrate judge initially supported the hearing officer’s conclusion, he acknowledged that L.I.’s suicide attempt was sufficient to “trigger eligibility for special services” (Mr. I. v. Maine School Administrative District No. 55, 2007). While the court denied the parents’ request for reimbursement, finding that The Community School did not provide services reasonably designed to meet her special education needs, it emphasized that the IEP developed for L.I. should reflect the district’s earlier failure to recognize and address her eligibility. Based on the evidence of her emotional and social challenges, the district court ultimately determined that L.I. met the eligibility criteria under the Individuals with Disabilities Education Act (IDEA).

Impact

Mr. I. v. Maine School Administrative District No. 55 (2007) affirmed that mental health

conditions can qualify as disabilities under the IDEA. The court clarified that emotional

disturbances and other health impairments are covered by IDEA but only when they adversely affect a child’s educational performance. It emphasized that even students with strong academic records may still be eligible for services if their mental health challenges interfere with their ability to access education. The decision supports a broader interpretation of educational performance, stating that any negative effect may be sufficient to establish eligibility.

Court Documents

Mr. I. v. Maine School Administrative District No. 55 (2007)

Citations

Mr. I. v. Me. Sch. Admin. Dist. No. 55, 480 F.3d 1 (1st Cir. 2007).