Stuart v. Nappi (1978)

By Nicole Tursellino

Overview

Kathy Stuart was a young high school student who had disabilities and a history of disciplinary issues. When the school sought to expel Kathy due to her disruptive behavior, her family sued, arguing that this violated her right to Free Appropriate Public Education as an individual with disabilities. The U.S. District Court for the District of Connecticut ruled in favor of Stuart, stating that expulsion would be a violation of her rights under the Education for All Handicapped Children Act of 1975. 

Summary

Kathy Stuart, a student with disabilities that often had emotional and academic difficulties, was in her third year attending Danbury High School when the Danbury Board of Education held an expulsion hearing seeking to remove her from their system. The School claimed that this was due to her being academically deficient, along with her having complex learning disabilities and limited intelligence. She also had behavioral issues. After receiving a psychological assessment, it was revealed that the “plaintiff had severe learning disabilities derived from either a minimal brain dysfunction or an organically rooted perceptual disorder.” With this, the Planning and Placement Team (PPT) in which Kathy was referred to recommended she be placed in a handicapped program at her school. However, for over a year, Kathy did not receive these services, and it was unclear if it was a lack of the school providing this assistance or Kathy not attending on her own accord. About a year later, Kathy was involved in a school-wide disruption that caused her to have a ten-day suspension and a hearing for expulsion, where she was to be expelled for the remainder of the 1977-1978 school year.

Stuart’s parents sued the school district, stating that she had been denied the rights provided to her by the Education for All Handicapped Children Act of 1975. The purpose of the act was to provide states with federal funding to provide public education to handicapped individuals. The U.S. The District Court for the District of Connecticut ruled in Stuart’s favor, claiming that her behaviors were linked to her disabilities. The court stated that “the right to an education in the least restrictive environment may be circumvented if schools are permitted to expel handicapped children.” This would jeopardize handicapped individuals' right to an education and is inconsistent with the Education for All Handicapped Children Act of 1975. The Danbury Board of Education was ordered to require an immediate PPT of Kathy’s education plan.

Impact

The ruling of this decision demonstrated the power of the Education for All Handicapped Children Act of 1975 and showed that individuals with disabilities could not be discriminated against because of their actions that were caused as a result of their disabilities. This case prevented further students with disabilities from being expelled from public schools in the future due to actions caused by their disability. This case heightened awareness around Free Appropriate Public Education (FAPE), highlighting that schools are required to provide education that is tailored to the needs of each student with disabilities. Furthermore, it demonstrated that school’s must determine the extent of a student's actions in conjunction with their disabilities before taking disciplinary action against them. This laid the foundation for other cases regarding violations of FAPE and the rights provided by it. 

Additional Documents

To learn more about the Education for All Handicapped Children Act of 1975, click here: https://www.gao.gov/products/113316

To read more about the case, click here: https://law.justia.com/cases/federal/district-courts/FSupp/443/1235/1953427/

To learn more about Free Appropriate Public Education, click here: https://www.understood.org/en/articles/what-is-and-isnt-covered-under-fape

To learn more about Planning and Placement Teams, click here: https://ipsworks.org/index.php/what-is-ips/

Citations

Lee, Andrew. “What’s Covered under FAPE - Free Appropriate Public Education.” Www.understood.org, 2022, www.understood.org/en/articles/what-is-and-isnt-covered-under-fape.

Noel, Valerie. “What Is IPS?” The IPS Employment Center, ipsworks.org/index.php/what-is-ips/.

“Stuart v. Nappi, 443 F. Supp. 1235 (D. Conn. 1978).” Justia Law, law.justia.com/cases/federal/district-courts/FSupp/443/1235/1953427/.

U. S. Government Accountability. “The Education for All Handicapped Children Act of 1975.” Www.gao.gov, 10 Sept. 1980, www.gao.gov/products/113316.