Town of Burlington v. Department of Education of Massachusetts (1985)

By Lauren Fantroy-Winston

Overview

In Town of Burlington v. Department of Education for the Commonwealth of Massachusetts,

John Doe, the plaintiff, was a student with disabilities attending school in the Town of

Burlington, the defendant. His parents challenged both his individualized education program

(IEP) and his school placement by requesting an administrative review.

Summary

This case centered around John Doe Jr., a 9-year-old student with learning disabilities.

Burlington placed him in a public-school classroom under the instruction of Mr. McAleer. After

a due-process hearing, the Massachusetts Department of Education's hearing officer determined that Burlington’s IEP was insufficient to meet Doe’s needs and ordered the town to cover the cost of private school tuition for him. Burlington subsequently filed a lawsuit in federal district court against both the state and Doe, challenging the hearing officer’s decision under federal and state law, while also requesting a stay on the tuition payment order, which the court denied.

The district court granted summary judgment in favor of Doe and the state, but Burlington

appealed to the First Circuit. The appellate court vacated the summary judgment, dismissed the state-law claims, and sent the federal claims back for trial. On remand, the district court ruled that Burlington’s IEP was appropriate and ordered Doe to reimburse the town for the private-school tuition it had paid. Doe and the state appealed to the First Circuit, arguing that the district court failed to give proper deference to the administrative record and incorrectly applied provisions of the Individuals with Disabilities Education Act (IDEA) regarding the inclusion of additional evidence during judicial review. The First Circuit partially reversed, partially affirmed, and remanded the case, providing guidance on the standards the lower court should follow regarding deference and evidentiary matters.

The United States Supreme Court granted certiorari and ruled that courts have the authority under § 1415(e)(2) to require school districts to reimburse parents for private special education costs if the court determines the private placement is appropriate under the IDEA. The Court emphasized that denying reimbursement would undermine the child's right to a free appropriate public education and the parents' ability to fully participate in the IEP process. Additionally, the Court held that parents who move their child to a private school during a dispute over an IEP do not forfeit their right to seek reimbursement for private tuition. If, however, the courts ultimately find the IEP to be appropriate, the parents would not be entitled to reimbursement for the time their child was placed in private school in violation of § 1415(e)(3).

Impact

The U.S. Supreme Court ruled that if parents place their child in a private school due to an

insufficient IEP, they may be entitled to reimbursement from the public school if the court later determines that the IEP was inadequate under the IDEA. While courts should give some deference to the decisions made by administrative hearing officers, they also retain the authority to independently evaluate the suitability of an IEP and the child’s placement.

The Court further held that parents do not lose their right to reimbursement by moving their child to a private school while disputes over the IEP are ongoing, ensuring they are not forced to keep their child in an inappropriate educational setting during legal proceedings.

In summary, the decision in Town of Burlington v. Department of Education for the

Commonwealth of Massachusetts enhanced the procedural protections for parents and students under the IDEA. It allowed parents to seek appropriate placements without financial risk and clarified the level of judicial authority in granting remedies under the IDEA Act.

Court Documents:

To read more about Town of Burlington v. Department of Education for the Commonwealth of

Massachusetts click here: https://supreme.justia.com/cases/federal/us/471/359/

To read more about Town of Burlington v. Department of Education for the Commonwealth of

Massachusetts click here:

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To read more about Town of Burlington v. Department of Education for the Commonwealth of

Massachusetts click here: https://www.quimbee.com/cases/town-of-burlington-v-department-of-