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Cedar Rapids v. Garret F.
Citation: Not availableDocket: 96-1987
Court: Court of Appeals for the Eighth Circuit; February 6, 1997; Federal Appellate Court
Original Court Document: View Document
The case No. 96-1987 NICR involves an appeal from the Cedar Rapids Community School District regarding the provision of continuous nursing services for Garret F., a minor with a spinal cord injury, under the Individuals with Disabilities Education Act (IDEA). The district court ruled in favor of Garret, determining that the required nursing services were not classified as 'medical services' excluded by the IDEA but rather as 'related services' that the school district must provide. Garret, who became a quadriplegic and dependent on a ventilator after a motorcycle accident at age four, has attended school in the Cedar Rapids Community School District since kindergarten, requiring constant health care support. Initially, his family provided this support until an agreement ended when he entered fifth grade. Garret's mother requested the school district to take over these nursing services, which the district refused, leading to an administrative challenge. An administrative law judge ruled in favor of Garret, requiring reimbursement for nursing costs and future provision of services. The school district appealed this decision to the U.S. District Court, which upheld the administrative ruling and granted summary judgment for Garret. The court's interpretation of the IDEA will be reviewed de novo on appeal, emphasizing that states must ensure all children with disabilities have the right to a free appropriate public education to receive IDEA funding. The term "free appropriate public education" encompasses special education and related services per 20 U.S.C. 1401(18). If Garret's nursing services are classified as "related services," the school district is obligated to provide them. Related services include a range of supportive services aimed at assisting children with disabilities to benefit from special education, as detailed in 20 U.S.C. 1401(a)(17). Garret argues his nursing services fall under this category, while the school district contends they are "medical services," which are excluded from supportive services. The court applies a two-step test from the Supreme Court's ruling in Irving Indep. School Dist. v. Tatro, 468 U.S. 883 (1984). First, the court determines if Garret's services are supportive services necessary for benefiting from special education. There is consensus that these services are essential for Garret's ability to attend school and benefit from education. Thus, they are deemed supportive services under IDEA. Next, the court assesses whether these services are excluded as medical services beyond diagnosis or evaluation. According to Tatro, physician services (except for diagnostic purposes) are excluded, while services provided by a nurse or qualified layperson are not. Since Garret's services are delivered by a nurse rather than a physician, they qualify as school health services or supportive services, thereby fulfilling the definition of related services that the district must provide. The court acknowledges differing interpretations of Tatro, but it adheres strictly to the physician/non-physician distinction established by the Supreme Court, rejecting broader interpretations that consider the nature or extent of services. Consequently, the court affirms the district court's judgment.