Narrative Opinion Summary
The case involves an appeal by the Springdale School District against a district court ruling favoring Sherry Grace, a profoundly deaf minor, her parents, and the Arkansas State Department of Education. The court addressed the requirements of the Education for All Handicapped Children Act, determining that Springdale School could provide Sherry with a free appropriate education, compliant with the Act's mainstreaming mandates. Sherry had previously attended the Arkansas School for the Deaf, where she made significant progress, but the court ruled that Springdale's Individualized Education Program (IEP), offering instruction from a certified teacher of the deaf, was adequate. The court applied the Rowley standard, which defines an appropriate education as one that allows handicapped children to progress academically alongside nonhandicapped peers. Despite acknowledging that the School for the Deaf might provide superior education, the court emphasized the Act's requirement of providing an 'appropriate' rather than the best education. The district court's decision was affirmed by the Second Circuit, focusing solely on federal law and dismissing considerations of state law. The ruling stipulated that Sherry's education at Springdale would include interaction with nonhandicapped peers, consistent with federal standards. The decision was particular to Sherry's case and reaffirmed the preponderance of evidence supporting the district court's judgment.
Legal Issues Addressed
Appropriate Education under the Rowley Standardsubscribe to see similar legal issues
Application: The district court used the Rowley standard to define 'appropriate education,' determining that it allows progress between grades and the opportunity to reach full potential alongside nonhandicapped peers.
Reasoning: The district court adopted the Rowley standard, emphasizing that opportunities for handicapped children should be commensurate with those for nonhandicapped children.
Education for All Handicapped Children Act Requirementssubscribe to see similar legal issues
Application: The district court found that Springdale School could provide a free appropriate education for Sherry Grace, satisfying the Act's requirements.
Reasoning: The district court determined that under the Education for All Handicapped Children Act, the Springdale School could provide Sherry with a free appropriate education and upheld the Individualized Education Program (IEP) developed for her.
Federal vs. State Law Jurisdictionsubscribe to see similar legal issues
Application: The district court limited its review to federal law, dismissing considerations under Arkansas law as the case sought federal review.
Reasoning: The Springdale School's argument to consider Arkansas law was deemed without merit as the complaint sought review under federal law, specifically section 1415(e) of the Act.
Individualized Education Program (IEP) Requirementssubscribe to see similar legal issues
Application: Springdale School's IEP was designed to address Sherry's unique educational needs with instruction from a certified teacher of the deaf.
Reasoning: The Springdale School developed an Individualized Education Program (IEP) for Sherry, a student with significant academic deficits, recommending instruction by a certified teacher of the deaf using total communication.
Mainstreaming Requirement under the Actsubscribe to see similar legal issues
Application: The court concluded that Springdale School met the Act's mainstreaming requirements by allowing Sherry to interact with nonhandicapped peers.
Reasoning: The court also confirmed that the school met the mainstreaming requirements of the Act and granted an injunction for a certified teacher for the 1980-81 term while denying attorney fees.