Schaffer v. Weast (2005)

By Nityanshi Rao

Overview

Schaffer v. Weast (2005) determined that the burden of proof in disputes over a child's Individualized Education Program (IEP) under the Individuals with Disabilities Education Act (IDEA) lies with the party challenging the IEP.

Summary

Jocelyn and Martin Schaffer, the parents of Brian Schaffer, a child with learning disabilities and speech impairments, brought a lawsuit against Montgomery County Public Schools, specifically naming the school district’s superintendent, Jetty Weast, as the respondent. Brian had attended private school for several years, but as he was preparing for eighth grade, the private school informed his parents that they could no longer meet his educational needs. The Schaffers then approached the public school system for assistance, as required under IDEA.

IDEA ensures that children with disabilities are entitled to a "free appropriate public education" (FAPE). It mandates that schools develop an Individualized Education Program (IEP) for each student with disabilities to meet their specific educational needs. The public school created an IEP for Brian, but the Schaffers found it inadequate, arguing that it did not provide the necessary services for their son to make appropriate academic progress. The Schaffers subsequently enrolled Brian in another private school and requested a due process hearing to challenge the IEP and seek reimbursement for the private school tuition.

In the initial hearing, the Administrative Law Judge (ALJ) ruled in favor of the school district, determining that the parents, as the challengers, bore the burden of persuasion to prove that the IEP was inadequate. Dissatisfied, the Schaffers appealed to the district court, which reversed the ALJ's decision, stating that the school district should bear the burden of proof because it was responsible for creating the IEP. This ruling was significant because, at the time, there was no clear guidance in IDEA regarding which party should bear the burden of proof in disputes over the sufficiency of an IEP.

The Fourth Circuit Court of Appeals then heard the case and overturned the district court’s ruling. It reinstated the ALJ's decision, concluding that the traditional legal principle—placing the burden of proof on the party seeking relief—applied in this case, meaning the Schaffers, as the plaintiffs, had the responsibility to prove that the IEP was insufficient. The Fourth Circuit emphasized that in most legal proceedings, the burden of proof lies with the party who initiates the action, absent any statutory provisions to the contrary.

The U.S. Supreme Court granted certiorari to resolve this issue. On November 14, 2005, in a 6-2 decision, the Supreme Court affirmed the Fourth Circuit’s ruling, holding that the burden of persuasion in IDEA disputes rests with the party seeking relief. Writing for the majority, Justice Sandra Day O’Connor stated that because IDEA is silent on the issue of burden of proof, the Court would follow the default legal rule, which places the burden on the party initiating the case. In this situation, the Schaffers, as the parents challenging the IEP, had the responsibility to demonstrate that the program did not provide Brian with the required FAPE.

The Court rejected several arguments made by the Schaffers. First, they argued that placing the burden of proof on parents would make it harder for them to obtain the educational services their children needed, given that school districts often have greater resources and expertise. Justice O’Connor acknowledged this concern but pointed out that IDEA provides numerous procedural safeguards to ensure that parents have access to the information they need to make their case, including the right to review educational records and to seek independent evaluations. The Court also emphasized that shifting the burden of proof to school districts would not necessarily improve the quality of IEPs but might instead divert resources away from educational services and into litigation.

In dissent, Justice Ruth Bader Ginsburg argued that school districts should bear the burden of proof because they have more expertise and resources. She expressed concern that placing the burden on parents could make it more difficult for them to obtain necessary services for their children. Justice Stephen Breyer, in a separate dissent, argued that the allocation of the burden of proof should vary depending on state regulations and the nature of the dispute.

The ruling had broad implications for the special education community. By reaffirming the traditional rule that the burden of proof lies with the party seeking relief, the decision made it clear that parents challenging an IEP must come to the hearing prepared with sufficient evidence to demonstrate that the school district’s proposed program is inadequate. However, the Court also noted that school districts would bear the burden of proof if they sought to change a child’s educational services or challenged a parent’s request for independent evaluations.

Impact

The Schaffer v. Weast decision established a precedent that parents bear the burden of proof when challenging the adequacy of their child’s IEP under IDEA, unless state law provides otherwise. This ruling aligned special education disputes with general legal principles and clarified that school districts are not presumed to be at fault when their educational plans are contested.

For parents, the decision emphasized the importance of gathering evidence and expert testimony to demonstrate the inadequacy of an IEP. The Court’s decision, however, did not leave parents without recourse. IDEA contains procedural safeguards that provide parents with access to educational records, the right to request independent evaluations, and the opportunity to seek impartial due process hearings.

For school districts, the decision reduced the likelihood of automatically shouldering the burden in IEP disputes, easing potential litigation costs. However, school districts still face the burden of proof when seeking to enforce changes to a child’s educational program or when contesting a parent’s request for additional services.

While the decision generally favored school districts, the Court’s reaffirmation of the procedural protections available to parents was a reminder that the system is designed to ensure fairness and access to necessary information for both parties.

Sources

Court Documents

To read the full Supreme Court Opinion and Dissents for Schaffer v. Weast, click here:

Schaffer v. Weast, 546 U.S. 49 (2005)https://supreme.justia.com/cases/federal/us/546/49/

To read the Court of Appeals Fourth Circuit 2004 Opinion, click here:

Schaffer v. Weast, 377 F.3d 449 (4th Cir. 2004)https://law.justia.com/cases/federal/appellate-courts/ca4/03-1199/03-1199-2004-08-12.html

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

Citations

• Schaffer v. Weast, 546 U.S. 49 (2005)

• Schaffer v. Weast, 377 F.3d 449 (4th Cir. 2004)

• Conroy, Terrye; Yell, Mitchell L.; Katsiyannis, Antonis. "Schaffer v. Weast." Remedial and Special Education.

• Wright, Peter W. D., Esq. "Schaffer v. Weast: How Will the Decision Affect You?" Wrightslaw.com, 2024.