Timothy W. v. Rochester, New Hampshire, School District (1989)
- Sam Shepherd
- Feb 10
- 3 min read
Updated: Jul 25
By Davina Haggar
Overview
In Timothy W. v. Rochester, New Hampshire, School District (1989) the First Circuit Court of Appeals addressed the proper educational rights for a child with severe disabilities. The Rochester School District refused to provide Timothy with special education services granted under the Individuals with Disabilities Education Act (IDEA), arguing that his disabilities were too severe for him to make educational progress. However, Timothy’s mother argued that he is capable of benefiting from these services, so she filed a lawsuit against the school district. She claimed that the school district violated IDEA, which guarantees children with disabilities access to a Free and Appropriate Public Education (FAPE).
Summary
In December 1975, Timothy W. was born prematurely and experienced severe respiratory problems, intracranial hemorrhage, subdural effusions, seizures, hydrocephalus, and meningitis (Justice U.S. Law). As a result of these conditions, Timothy became severely handicapped with developmental disabilities, spastic quadriplegia, cerebral palsy, and color blindness, all of which significantly impacted his ability to learn (Britannica). Timothy’s pediatrician advised that he should have a specialized program to meet his needs. However, two other pediatricians claimed that Timothy had no potential for educational progress.
The Rochester school district concluded that Timothy would be incapable of benefitting from an education and therefore refused to provide Timothy with any specialized educational programs. Although he received limited services from the Rochester Child Development Center, he was denied the tailored educational programs granted under IDEA.
School board officials reconvened in 1983 to reassess Timothy’s situation and many officials suggested a specialized program that focuses on physical therapy, as that is what would help him most. However, they still refused to meet his needs.
Timothy’s attorney filed a complaint with the state education agency, which ordered the school district to provide him with educational services, yet the board refused again. As a result, Timothy’s attorney filed a lawsuit in federal district court, arguing that the Rochester School Board breached a number of laws. The district court ruled in favor of the Rochester School Board, arguing that they are not required to provide Timothy with special-education services because he would not benefit from them (Britannica). In 1989, this case was argued before the First Court of Appeals. The court ruled that under the Education for All Handicapped Students Act, all children with qualifying disabilities, including Timothy, were entitled to proper educational services and support. They ruled that even if a child appears to be “uneducable,” they are still entitled to the protections and services under the EAHCA. The court emphasized that children with the most severe disabilities should be prioritized for such protections. The decision of the court was reversed.
Impact
The court’s ruling declared that the EAHCA enforces a “zero-reject policy,” ensuring that no child, regardless of the severity of their disabilities, can be rejected educational services because they may not appear to benefit from them (Justia U.S. Law). This ruling declared that all disabled students are entitled to receive the protections and services under EAHCA, regardless of their progress or level of achievement.
Court Documents
Citations
Alexander Hager-DeMyer, Alexander. “Timothy W. v. Rochester, New Hampshire School District.” Quimbee, www.quimbee.com/cases/timothy-w-v-rochester-new-hampshire-school-district. Accessed 4 Feb. 2025.
Samuels, Christina A. “Landmark Special Ed. Case Confirming ‘zero Reject’ Rule Marks 25 Years.” Education Week, Education Week, 19 Nov. 2020, www.edweek.org/policy-politics/landmark-special-ed-case-confirming-zero-reject-rule-marks-25-years/2014/12.
Steketee, Amy M. “Special Education.” Encyclopædia Britannica, Encyclopædia Britannica, inc., 15 Jan. 2025, www.britannica.com/topic/special-education.