Smith v. Robinson (1984)

By Davina Haggar

Overview

In Smith v. Robinson (1984), the Supreme Court addressed the needs of Tommy Smith, an eight-year-old boy who was diagnosed with cerebral palsy and other physical and emotional disabilities. Tommy’s family concluded that the public school he had attended did not suit his needs and decided to enroll him into a private school. However, the school district denied paying for Tommy’s tuition at the private school, claiming that the public school adequately fits his needs, so Tommy’s family filed a lawsuit against the local school district. They argued that the school district’s denial to pay for Tommy’s private school tuition and reimburse their attorney’s fees violated the Education for All Handicapped Children Act (EAHCA)

Summary

Tommy Smith, a young child with several disabilities, lived and attended a school in Cumberland, Rhode Island. He suffered from cerebral palsy, a group of medical conditions that impacts one’s movement and posture, caused by damage to the developing brain (Cerebral Palsy). Cerebral Palsy can cause several challenges in school including a short attention span, language challenges, and difficulty with motor planning (How Cerebral Palsy Affects People). Tommy’s parents claimed that these conditions interfered with his education at the public school and the school district did not provide him with proper services, which are granted under Individuals with Disabilities Education Act (IDEA). EAHCA was the predecessor of IDEA, a federal law that ensures children with disabilities receive free and appropriate education to meet their needs (U.S. Department of Education). 

Tommy’s parents felt that their child's needs were not met at the public school due to a  lack of specialized programs. To address this, they enrolled him in a private institution better equipped to support him. After making this decision, his parents requested that the local school district cover the costs of Tommy’s private school tuition, arguing that the public school failed to meet his needs under EAHCA. 

However, the school district refused to cover those costs, asserting that the public school would provide Tommy with tailored programs to support him. This disagreement prompted the parents to sue the local school district for the difficulties they endured while trying to provide their son with the educational support he deserves as a child with disabilities.

The lower courts ruled that the school district had failed to supply Tommy with the education he was entitled to under EAHCA. They ordered the school district to reimburse Tommy’s family for the private school tuition but denied the reimbursement of attorney’s fees, as EAHCA did not explicitly cover such expenses. This denial led to the case being appealed to the Supreme Court to determine whether the Smith family was entitled to be reimbursed for the expenses spent on attorney’s fees. They ruled this way because the EAHCA does not explicitly take responsibility for covering such fees. This decision introduced significant criticism, as such expenses can create financial barriers for families of children with disabilities advocating for their child’s educational rights.

Impact

Smith v. Robinson shined a light on the gaps in protecting disabled children and emphasized the importance of educational services that are tailored to them. The U.S. Supreme Court’s decision not to reimburse the Smith family for attorney’s fee, which they should not have had to cover under the rights granted by EAHCA, highlighted the financial struggles families face to support their child's needs. This criticism prompted Congress to pass the Handicapped Children’s Protection Act, introduced in 1985 and signed into law in 1986, allowing families to recover such expenses in similar cases (Handicapped Children's Protection Act of 1986). 

Court Documents

Smith v. Robinson

Handicapped Children's Protection Act of 1985

The Handicapped Children's Protection Act of 1986

Smith v. Robinson

Smith v. Robinson 

Citations

“Cerebral Palsy.” Mayo Clinic, Mayo Foundation for Medical Education and Research, 28 Sept. 2023, www.mayoclinic.org/diseases-conditions/cerebral-palsy/symptoms-causes/syc-20353999. Accessed 25 Jan. 2025.

“Education Rights for Students with Disabilities.” Pacific ADA Center, 10 Oct. 2023, www.adapacific.org/education-rights-for-students-with-disabilities/. Accessed 24 Jan. 2025.

Foundation, Cerebral Palsy Alliance Research. “How Cerebral Palsy Affects People.” Cerebral Palsy Alliance Research Foundation, cparf.org/what-is-cerebral-palsy/how-does-cerebral-palsy-affect-people/. Accessed 24 Jan. 2025.

“Individuals with Disabilities Education Act (IDEA).” U.S. Department of Education, www.ed.gov/laws-and-policy/individuals-disabilities/idea. Accessed 23 Jan. 2025.

Yell ML. “The Handicapped Children’s Protection Act of 1986: Time to Pay the Piper?” Exceptional Children, U.S. National Library of Medicine, pubmed.ncbi.nlm.nih.gov/2137417/. Accessed 26 Jan. 2025.