Skip to main content
Special Education Law
Sign In

Board of Ed Appoquinimink, et al. v. Sqj, v., et al.

November 25, 2008

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

THE BOARD OF EDUCATION OF THE APPOQUINIMINK SCHOOL DISTRICT,

Plaintiff,

Vv. : Civil Action No. 06-770-JJUF

JULIE JOHNSON AND SAMUEL QUINTON, JOHNSON IV, parents of SQJ, V

Defendant.

Scott A. Holt, Esquire and Michael P. Stafford, Esquire of YOUNG CONAWAY STARGATT & TAYLOR, LLP Wilmington, Delaware. Attorneys for Plaintiff.

Wayne D. Steedman, Esquire of CALLEGARY & STEEDMAN, P.A., Baltimore, Maryland. Bruce L. Hudson, Esquire of LAW OFFICE OF BRUCE L. HUDSON, ESQUIRE, Wilmington, Delaware Attorneys for Defendant.

MEMORANDUM OPINION

“ November do, 2008 Wilmington, Delaware.

Farnan, Lstrjic ACee SD. Pending before the Court is Defendants’ Motion To Stay

Pending Appeal. (D.I 51.) For the reasons discussed, the Court

will deny the Motion.

I. BACKGROUND

The background relevant to this action has been set forth

fully in the Court’s decision (D.I. 46) granting summary judgment

in favor of Plaintiff, the Board of Education of the

Appoquinimink School District (the “District”). By way of

summary, Plaintiff filed this action pursuant to 20 U.S.C. §

1415{i) (2)-{(3) seeking judicial review of an administrative

hearing decision rendered by the Administrative Hearing Panel

(the "Panel") in connection with a complaint filed by Defendants

alleging that their minor son's educational needs were not being

met in the public school system, and therefore, he should be

placed in St. Anne's Episcopal School (St. Anne's), a private

school, at public expense. Defendants’ son (the “student”) is a

twelve year old deaf child who is eligible to receive special

education and related services under the Individuals with

Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq. and

14 Del. C. § 3103 et seq.

Although the Panel concluded that the District complied with

the IDEA by providing the student with a free appropriate public

education ("FAPE"), and therefore, the District was not required

to fund the student’s placement at St. Anne’s, the Panel

concluded that the District failed to properly exercise its

discretion when it declined to provide the student with a full-

time sign language interpreter while he attends St. Anne’s. On

summary judgment, the Court reversed the Panel’s decision as it

applied to the provision of a publicly funded full-time

interpreter for the student.

Defendants appealed the Court’s decision, and filed the

instant Motion seeking a stay pending appeal and requesting the

District to continue to pay for the student’s interpreter pending

a ruling from the Court of Appeals for the Third Circuit on their

appeal. The Motion has been fully briefed and is ripe for the

Court’s review.

Ii. THE PARTIES’ CONTENTIONS

By their Motion To Stay Pending Appeal, Defendants contend

that under 20 U.S.C. § 1415(j), the “stay-put” provision of the

IDEA, the District is responsible for continuing to pay for the

student’s interpreter pending the resolution of Defendants’

appeal. Defendants contend that the stay-put provision applies

to both administrative and judicial proceedings, and requires the

student to stay in his current educational placement during these

proceedings. Referring to 20 U.S.C. § 1415(j), 34 C.F.R. §

300.518 and judicial decisions interpreting those provisions,

Defendants contend that the student’s current educational

placement is defined by the Panel’s decision. Therefore,

Defendants maintain that the student is a parentally placed

private school student at St. Anne’s, who is entitled to receive

special education services in the form of an ASL interpreter, at

least until the resolution of this appeal.

In response, the District contends that St. Anne’s does not

constitute the student’s current educational placement under the

Panel’s decision, because the Panel rejected Defendants’ argument

that the student required private placement, at public expense,

at St. Anne’s in order to receive a FAPE. The District contends

that a contrary ruling would “obliterate the distinction between

students with disabilities who attend private school at public

expense in order to receive FAPE and those, such as [the student

here], who attend private school at their parents’ choice despite

the fact that a FAPE is available to them in the public schools.”

(D.I. 58 at 4-5). In the alternative, the District contends that

even if St. Anne’s is considered the student’s current

educational placement, the stay-put provision only applies

through initial judicial review of an administrative order and

does not apply throughout the entire judicial appeals process.

Because the stay-put provision of the IDEA does not apply, the

District contends that Defendants must demonstrate that a stay

pending appeal is appropriate under the common law requirements

for a stay pending appeal. The District points out that

Defendants have not made this alternative argument and in any

event, contends that Defendants cannot demonstrate that those

requirements are met here.

III. DISCUSSION

The stay-put provision of the IDEA provides:

[D]uring the pendency of any proceedings conducted pursuant to this section, unless the State or local educational agency and the parents otherwise agree, the child shall remain in the then-current educational placement of the child, or, if applying for initial admission to a public school, shall, with the consent of the parents, be placed in the public school program until all such proceedings have been completed.

20 U.S.C. § 1415(4). In this case, the parties dispute both the

student’s “then-current educational placement,” and if that

placement is at St. Anne’s with a publicly funded full-time ASL

interpreter, whether that placement continues through the

pendency of an appeal to the Third Circuit.

A. Whether The Student’s Then-Current Educational Placement Includes The Provision Of A Publicly Funded ASL Interpreter Even Though He Is A Parentally Placed Private School Student

Discussing the Supreme Court’s ruling in School Comm. of the

Town of Burlington v. Dep’t of Educ., 471 U.S. 359, 361 (1985),

the Third Circuit explained that “a ruling by the education

appeals panel in favor of the parents’ position constitutes

agreement for purposes” of defining the child’s then current

educational placement under the stay-put provision. Susquenita

Sch. Dist. v. Raelee, 96 F.3d 78, 81 (3d Cir. 1996). This

principle is echoed in the regulations which provide:

If the hearing officer in a due process hearing conducted by the SEA or a State review official in an administrative appeal agrees with the child's parents that a change of placement is appropriate, that placement must be treated as an agreement between the State and the parents for purposes of paragraph (a) of this section [which refers to a child’s current educational placement].

34 C.F.R. § 300.518(d). The Third Circuit has also concluded

that the stay-put provision encompasses not only the actual

physical placement of the child, but also the provision of

disputed services to the child. Pardini v. Allegheny Intermed.

Unit, 420 F.3d 181, 192 (3d Cir. 2005) (holding that the child

could continue to receive disputed service until the dispute over

its appropriateness was resolved).

The difficulty in this case, however, is that the Panel

specifically rejected Defendants’ contention that the student

required private placement, at public expense, at St. Anne’s in

order to receive a FAPE, and went on to base its holding in favor

of the parents regarding the provision of services on the

District’s alleged failure to properly exercise its discretion to

provide a publicly funded ASL interpreter. That the Panel’s

decision was based on a review of the District’s discretionary

judgment and not on the failure of the District to provide the

child with a FAPE is a circumstance unlike the circumstances in

either Pardini or Susquenita. In Susgquenita, the state education

appeals panel found that the Individualized Education Plan

(“IEP”) proposed by the District for the student was deficient

and that the program offered in the private school was more

appropriate for the student. 96 F.3d at 79. In determining

pendent placement for the child, the Third Circuit accepted the

appeals panel decision in light of the Supreme Court’s decision

in Burlington that the appeals panel ruling in favor of the

parents constitutes agreement for purposes of identifying the

child's current placement under the stay-put provision. In

Pardini, the circumstances were quite different in that they

concerned a child who was transitioning between Part C and Part B

of the IDEA. As a result, the child had in place an

Individualized Family Services Plan (“IFSP”) that included

conductive education when the dispute arose. However, the

hearing officer concluded that the Allegheny Intermediate Unit

(“AIU”) was not required to continue those services. Since the

parties’ dispute arose before an IEP was implemented, the Third

Circuit, emphasizing the need to maintain the child’s status quo,

concluded that the child’s current educational placement was the

IFSP, because it was the placement in place at the time the

dispute arose, and not the prospective IEP proposed by the AIU

that had not yet been implemented.

In this case, the Panel disagreed with Defendants and

expressly recognized that the District had no obligation to fully

fund an interpreter for the student in order to provide him with

a FAPE. Rather, the Panel’s partially favorable decision for

Defendants was based solely on the Panel’s conclusion that the

District failed to properly exercise its discretion in a

nonarbitrary manner. The student here is a parentally placed

private school student, and unlike Susguenita, his IEP was not

deficient and the District here complied with its responsibility

of providing the student with a FAPE. That Defendants chose to

privately place the student is an elective choice, and therefore,

the Court agrees with Defendants that this elective choice,

absent a failure by the District to provide the child with a

FAPE, cannot be said to have been done with the agreement of the

District. Moreover, as the Court recognized in its previous

decision, the District has a much more limited responsibility

with regard to the provision of services for parentally placed

private school students. Accordingly, the Court cannot conclude

that the student’s current educational placement should be

considered St. Anne’s with the provision of a fully funded ASL

interpreter.

Cc. Whether Defendants are Entitled to a Stay Under Section 1415(4)’‘s “Stay Put” Provision

In the alternative, even if the Court concludes that St.

Anne’s with a fully funded interpreter is the student’s current

educational placement, the Court concludes that this placement

does not extend beyond the conclusion of review by this Court.

There is a split in authority concerning the question of whether

the stay-put provision is meant to apply to review of a district

court’s decision by a circuit court. Although the Third Circuit

has not expressly addressed this issue, it has been addressed by

other appellate courts. See Kari H. v. Franklin Special School

Dist., 125 F.3d 855 (6th Cir. 1997) (holding that Congress did not

intend the stay-put provision to apply during circuit court

review); Andersen v. Dist. of Columbia, 877 F.2d 1018 (D.C. Cir.

1989) (same). In addition, at least one district court in this

Circuit has addressed the question, and reached a result contrary

to that taken by the appellate courts. Ringwood Bd. of Educ. v.

K.H.J, 469 F. Supp. 2d 267 (D.N.Jd. 2006) (concluding that the

Stay-put provision applies throughout the entire judicial

process, including circuit court appeals).

Absent direct guidance from the Third Circuit, the Court is

inclined to follow the reasoning of the circuit courts that have

addressed this matter. These courts have considered the specific

purpose of the stay-put provision, which was “‘to prevent school

officials from removing a child from the regular public school

classroom over the parents’ objections pending completion of the

review proceedings.’” See e.g., Andersen, 877 F.2d 1018 at 1024

(emphasis in original) (quoting Burlington School Committee v.

Massachusetts Dep’t of Ed., 471 U.S. 359, 373 (1985)). As the

Andersen court went on to explain:

Once a district court has rendered its decision approving a change in placement, that change is no

longer the consequence of a unilateral decision by school authorities; the issuance of an automatic injunction perpetuating the prior placement would not serve the section’s purpose.

The Andersen court’s rationale takes on particular

Significance in this case, because the student is a parentally

placed private school student and the Panel did not find that his

placement at St. Anne’s was required to provide him with a FAPE.

Moreover, the Court has concluded that public funding of an ASL

interpreter is not required, and therefore, any change in the

provision of services engendered by this decision is the result

of judicial review and not any unilateral action by the District.

Further, the Court’s decision does not leave parents of

children eligible for special education and related services

under the IDEA without an opportunity to pursue injunctive

relief. Traditional common law principles of obtaining an

injunction remain available to parents seeking to maintain a

particular educational placement for their children pending

appeals beyond the district court. In this case, however,

Defendants have not invoked those common law principles.

Moreover, even if the Court considers the traditional

factors for injunctive relief here, the Court concludes that

Defendants cannot make the requisite showing. To obtain

injunctive relief for purposes of staying this Court’s judgment,

Defendants must show: (1) the likelihood of success on the

merits of their appeal, (2) irreparable harm will result to them

absent a stay, (3) there is no substantial harm to the opposing

party if a stay is issued, and (4) a stay is in the public

interest. See e.g., Republic of Phillippines v. Westinghouse

Flec. Corp., 949 F.2d 653, 658 (3d Cir.1991). In this case, the

Court concludes that Defendants cannot satisfy the second, third

or fourth prongs required for relief. Defendants cannot

demonstrate irreparable harm absent a stay, because retroactive

relief is available to them under the IDEA to seek reimbursement

for interpreter costs if they are ultimately successful on their

appeal. See e.g., Burlington, 471 U.S. 370-371. In contrast,

Defendants would be unlikely to be able to recoup the funds they

expend on an interpreter if this Court’s decision is affirmed.’

Further, the Court concludes that the public interest will not be

served by the provision of a full-time interpreter to the student

while he attends St. Anne’s. The purpose of the IDEA is to

“ensure that every child receives a ‘free and appropriate

education.’” Susquenita, 96 F.3d at 86-87. In this case, the

Panel concluded that a FAPE was available to the student in the

t While neither the United States Supreme Court nor the Third Circuit have addressed this issue directly, courts considering the issue have held that public school districts cannot recover funds spent on private school tuition and/or related services. See e.g., Clovis Unified School Dist. v. California Office of Administrative Hearings, 903 F.2d 635, 641 (9th Cir. 1990); Greenwich Bd. of Educ. v. Torok ex rel. J., 2003 WL 22429016, *3 n.7 (D. Conn. Oct. 22, 2003); Henry v. School Admin. Unit 29, 70 F. Supp. 2d 52, 59 (D.N.H. 1999).

District, and the student’s placement at St. Anne’s was not

required to ensure that he receive a FAPE. In these

circumstances, the Court cannot conclude that the cessation of

public funding for a full-time interpreter for the student, who

has been privately placed at the election of his parents, will

deprive the child of a FAPE or be at odds with the public

interest. To the contrary, the Court concludes that the public

interest is served by adhering to the statutory funding scheme

set forth in the IDEA for the provision of services to parentally

placed private school students, rather than placing the burden of

that funding solely and squarely on the taxpayers for the

duration of these proceedings. Accordingly, the Court will deny

Defendants’ Motion.

CONCLUSION

For the reasons discussed, the Court will deny Defendants’

Motion To Stay Pending Appeal.

An appropriate order will be entered.

11

D. Del.: Board of Ed Appoquinimink,... | Special Education Law