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K.L. v. RI Board of Education
Citation: 907 F.3d 639Docket: 17-1517P
Court: Court of Appeals for the First Circuit; October 29, 2018; Federal Appellate Court
Original Court Document: View Document
The case involves K.L. and her parent L.L., who challenge the Rhode Island Board of Education for allegedly failing to provide a free appropriate public education (FAPE) to eligible students with disabilities, as mandated by the Individuals with Disabilities Education Act (IDEA). K.L. asserts that while Rhode Island offers public education to non-disabled individuals aged 21 to 22, it does not extend the same special education services to qualifying individuals with disabilities in that age group. The dispute centers on the interpretation of "public education" in the IDEA, particularly regarding whether Rhode Island's adult education programs for non-disabled students qualify as "public education" under the Act. The district court ruled that these adult education programs do not meet the definition of "public education" within the context of the IDEA, thus concluding there is no discrimination against students with disabilities. However, the appellate court disagrees with this interpretation, vacating the district court's decision and remanding the case for judgment in favor of K.L. and for necessary remedial actions. The procedural history indicates that K.L. initially filed complaints on behalf of a certified class of individuals who were 21 but not yet graduated high school, and the district court had previously granted a statewide class certification. The court found minimal factual disputes regarding the Rhode Island Department of Education's supervision of adult education, which it deemed irrelevant to the "public education" definition. K.L. contends that, under the IDEA, Rhode Island is obligated to provide FAPE to students with disabilities up to age 22. The appellate review of the case involves a de novo assessment of the district court's summary judgment ruling and an interpretation of "public education" under the IDEA. The Individuals with Disabilities Education Act (IDEA) mandates that states provide a "free appropriate public education" (FAPE) to all children with disabilities aged 3 to 21. Eligible students may continue receiving special education services until age 22. However, there is an exception for children aged 18 to 21; states may not be required to provide FAPE to this group if it conflicts with state law, practice, or court orders regarding public education for the same age group. The Ninth Circuit interpreted this provision, stating that a state can only deny FAPE to students with disabilities aged 18 to 21 if it similarly does not provide public education to non-disabled students in that age range. The IDEA does not define "public education," indicating Congress's belief that the term has a commonly understood meaning, which includes significant state or local funding and public administration or oversight of educational services. This interpretation is accepted by both the court and the parties involved in the case. Appellees recognize that "public education" under the IDEA refers to education that meets state standards and is funded by the government. Various dictionary definitions support this understanding, indicating that "public education" involves government funding and oversight. The Oxford English Dictionary defines it as "education provided by the State," while the Random House Dictionary emphasizes that "public" means maintained at public expense and under public control, particularly in the context of public schools. These definitions align with the IDEA's concept of "free appropriate public education" (FAPE), which is characterized by being provided at public expense and supervised by the state. However, the definition of "public education" within the IDEA is limited to educational opportunities up to the completion of secondary school. This limitation is reflected in the IDEA's inclusion of "transition services" aimed at facilitating a child's movement from school to post-school activities, indicating that public education under the IDEA does not extend to post-secondary education. Additionally, FAPE is defined to include appropriate education at the preschool, elementary, or secondary levels, suggesting a direct correlation between the terms "public education" and FAPE in terms of educational levels covered. The scope of "public education" under the Individuals with Disabilities Education Act (IDEA) is affirmed by its purpose, which emphasizes secondary educational outcomes and graduation rates. "Public education" encompasses not only public funding and administration but also the goal of achieving academic proficiency equivalent to secondary school completion. Appellees argue that "public education" is limited to education provided in "traditional public schools," asserting that the services in question do not meet this definition and thus are not covered by the IDEA. They reference state and federal laws to support this narrow interpretation, which contradicts the IDEA's broad remedial purpose intended to protect the rights of children with disabilities. It is noted that such a limitation would restrict the eligibility of many students with disabilities, particularly those aged 18 to 21, for a Free Appropriate Public Education (FAPE). The court emphasizes that remedial legislation like the IDEA should be broadly interpreted. Appellees' reliance on Rhode Island state law to define "public education" is rejected, as the IDEA does not delegate this definition to states. Instead, the reference to state law pertains only to whether a state voluntarily provides education to students aged 18 to 21. Allowing states to define "public education" would lead to inconsistent interpretations across the country and could enable states to evade FAPE requirements. Ultimately, Rhode Island law is deemed an inappropriate guide for interpreting "public education" under the IDEA. Appellees reference 29 U.S.C. § 3272 of the Workforce Innovation and Opportunity Act (WIOA) and § 1401(34) of the IDEA to argue for a clear distinction between "public education" and "adult education," suggesting that if education is classified as adult education, it cannot also be considered public education, particularly if it occurs outside traditional public schools. However, the definition of "adult education" in the WIOA, established nearly forty years after the IDEA and focused on workplace development, does not support this claim. Appellees' argument relies on an incorrect application of the "whole code" canon of statutory interpretation, assuming Congress consistently drafted terms across different statutes, which lacks evidence. Furthermore, § 1401(34) of the IDEA lists "adult education" as a type of transition service aimed at improving the achievements of children with disabilities, but this inclusion does not imply that adult education is excluded from the definition of public education. Appellees fail to define "adult education" in the context of the IDEA and argue inappropriately that both "public education" and "adult education" are mutually exclusive without sufficient basis. Additionally, they cite a regulation defining "high school diploma" to assert that public education only occurs in traditional public schools, but this regulation clarifies that the obligation for free appropriate public education (FAPE) does not extend to children with disabilities who have graduated with a standard diploma, rather than excluding other forms of education. Overall, the appellees' interpretation is rejected as unfounded in the legislative context. Appellees argue that receipt of a non-traditional high school diploma should similarly disqualify publicly funded educational services aimed at achieving equivalency diplomas from being classified as "public education." However, this interpretation misreads the IDEA regulation. An equivalency diploma or alternative credential does not negate the classification of educational services leading to such diplomas as "public education." The regulation's intent is to prevent states from prematurely terminating FAPE services by issuing potentially inferior credentials, ensuring that services persist until a student demonstrates academic achievement equivalent to that of a regular high school diploma. This aligns with the IDEA’s goal of protecting the educational rights of students with disabilities, contradicting the appellees' argument for limiting access to special education services. The term "public education," as undefined by IDEA, is interpreted based on its ordinary meaning, which includes: (1) significant public funding, (2) public administration or oversight, and (3) education aimed at achieving academic competence typical of secondary school completion. Appellees' claim that "public education" should be restricted to traditional public schools lacks merit and undermines IDEA’s remedial purpose. The discussion shifts to whether Rhode Island provides such education up to age 22, thus necessitating FAPE provision for individuals with disabilities. Rhode Island's educational system mandates that individuals under 18 must regularly attend public day schools, with no explicit maximum age for attendance post-18. While most stop attending public schools by 18, the possibility of older students attending does not alone establish a state practice of providing public education to adults. Additionally, Rhode Island law guarantees the right to education for all citizens, leading to funding for community-based organizations that offer adult education services to individuals aged 21 to 22, alongside others. Rhode Island allocates funding to approximately thirty-four Community-Based Organizations (CBOs) to deliver adult education services, which include basic and secondary education, as well as programs for English language learners. These CBOs encompass various entities such as homeless shelters and municipal organizations. Unlike traditional public schools, which impose specific requirements like earning 20 credits across six core areas and maintaining a school year of at least 180 days, CBOs operate with more flexible criteria but remain under the oversight of the Rhode Island Department of Education. This oversight involves funding, accountability measures, setting performance targets, and potential funding withdrawal for inadequate performance. Rhode Island's regulations mandate that free appropriate public education (FAPE) be available to all eligible children aged 3 to 21, aligning partially with the Individuals with Disabilities Education Act (IDEA). However, Rhode Island law terminates FAPE at the age of 21, which raises questions about the compliance of adult education with IDEA standards. Specifically, it must be assessed whether Rhode Island's adult education system qualifies as "public education" under IDEA by meeting three criteria: significant public funding, public administration or oversight, and an objective of educating individuals to achieve a high school degree. The implications of this evaluation are crucial for students with disabilities between the ages of 21 and 22. Currently, if a student without disabilities fails to complete high school for non-disability reasons, they can access services to achieve academic proficiency and obtain a diploma. In contrast, students with disabilities who do not finish high school are not provided with equivalent services, highlighting a disparity in educational opportunities. To address whether this situation violates the IDEA's FAPE requirement, an examination of each attribute of "public education" is necessary. Funding for community-based organization (CBO) adult education programs in Rhode Island is primarily provided by the state, covering approximately eighty percent of total costs, with fee waivers available for some students. State law mandates the use of public funds for these services (R.I. Gen. Laws § 16-63-2(b)(3)), while the state’s general assembly retains discretion over funding decisions (R.I. Gen. Laws § 16-63-14). The Rhode Island Department of Education (RIDE) oversees adult education providers, ensuring that services are integrated and coordinated statewide (R.I. Gen. Laws § 16-63-2(b)(2)). RIDE employs accountability measures, including performance targets and potential sanctions such as funding withdrawal for inadequate performance. The administration of adult education includes various public agencies and institutions, emphasizing significant public involvement in these services (R.I. Gen. Laws § 16-63-9(a)). The primary objective of Rhode Island's adult education program is to help students achieve secondary education competency, providing opportunities for academic achievement up to grade twelve (R.I. Gen. Laws § 16-63-5(1)). The system prepares students for the GED exam or the National External Diploma Program (NEDP). Despite similar educational goals, some parties argue that adult education cannot be classified as "public education" due to differences in classroom hours and course requirements compared to traditional schools, as well as the "equivalency" designation on GED diplomas. However, the document argues that these distinctions lack a defensible basis, asserting that educational programs with public education attributes should not be differentiated solely by their delivery methods or settings. Rhode Island's regulations recognize the equivalency of traditional public schools and adult education programs by stating that an "Equivalency Diploma" holds the same status as a regular high school diploma. The dissent argues that these adult programs are not equivalent to traditional secondary education under the Individuals with Disabilities Education Act (IDEA), suggesting that they do not fulfill the educational needs of students with disabilities. However, this perspective misinterprets the IDEA's intent, which is to ensure students with disabilities can access various forms of public education, not just traditional settings. Rhode Island has made the choice to fund adult education programs aimed at helping individuals up to age 22 achieve secondary competencies, which necessitates that students with disabilities receive a Free Appropriate Public Education (FAPE) up to the same age. Concerns about potential financial burdens due to extending services to students with disabilities until their twenty-second birthday are unfounded, as Rhode Island already provides special education services until the end of the academic year in which a student turns 21. Thus, requiring parity in educational opportunities does not imply significant additional costs. The IDEA's purpose is to ensure equal educational opportunities for all students, indicating that reducing educational services for students with disabilities based on cost concerns is not acceptable. Overall, Rhode Island's adult education services qualify as "public education" under the IDEA, supported by substantial public funding from the state's education department. Rhode Island's adult education programs are subject to substantial oversight and aim to provide educational services comparable to those of public schools. These programs, which include secondary-level instruction, qualify as "public education" under the Individuals with Disabilities Education Act (IDEA), despite students paying a portion of the costs. This is because a significant majority (80%) of funding comes from the state, ensuring that students receiving such subsidies are engaging in public education. The argument that Rhode Island does not provide public education to residents over 18 is deemed irrelevant, as the adult education services fall within the IDEA's definition of public education. Additionally, although there are differing interpretations from the Ninth Circuit regarding the IDEA, this document does not adopt that perspective and thus does not address those arguments. The conclusion states that Rhode Island's law and practice comply with the IDEA's requirement to provide Free Appropriate Public Education (FAPE) to students with disabilities until their twenty-second birthday. Concerns raised by appellees about Community-Based Organizations (CBOs) being ill-equipped to provide compliant services are dismissed. The ruling confirms that while Rhode Island must ensure FAPE for students with disabilities up to age 22, it does not impose an obligation on CBOs to provide special education services. The resolution of how these services are delivered will be determined by the parties involved in subsequent proceedings. The court finds that Rhode Island's regulations under 300.101(a)(16) are noncompliant with the Individuals with Disabilities Education Act (IDEA) as outlined in 1412(a)(1)(A), rendering them invalid. The district court's judgment favoring the appellees is vacated, and a judgment in favor of the appellant is mandated. The district court is tasked with determining appropriate remedies in line with this ruling. The dissenting opinion, articulated by Circuit Judge Lynch, argues against the majority's interpretation of the IDEA, asserting that it incorrectly extends the obligation of Rhode Island school systems to provide special education to students until age 22. Lynch contends that the majority's definition of "public education" contradicts the statutory text, ordinary meaning, and congressional intent, asserting that it imposes undue financial burdens on local taxpayers and educational agencies. Lynch distinguishes "public education" as encompassing only preschool through secondary education, not adult education, which he claims does not meet the IDEA's criteria as it is neither free nor state-controlled. The dissent emphasizes that broadening the definition of "public education" oversteps the powers intended by Congress for state discretion. The majority's decision, according to Lynch, overlooks the lack of evidence that non-disabled students remain in public schools until age 22, which further underlines the inconsistency and potential consequences of the ruling. K.L. argues that under the Individuals with Disabilities Education Act (IDEA), "public education" includes "adult education," which would obligate Rhode Island to provide special education services to students until age twenty-two. Statutory interpretation mandates that statutes be understood in context within the broader legal framework, as established in Davis v. Michigan Dep't of Treasury. The IDEA aims to enhance the public school system's capacity to educate students with disabilities, addressing past exclusion and resource inadequacies that forced families to seek external services. The legislative history of the IDEA highlights the necessity of access to education for disabled students, mirroring the educational opportunities available to non-disabled peers. Specifically, the IDEA asserts that a Free Appropriate Public Education (FAPE) is required for students aged eighteen to twenty-one only if it aligns with the educational services provided to non-disabled students in that age group. The statute delineates that FAPE must be provided at public expense, under public oversight, and without charge, encompassing education from preschool through secondary school, which is defined as up to grade twelve. The interpretation affirms that "public education" refers to state-funded, state-controlled educational services from preschool through twelfth grade, thereby countering Rhode Island's assertion that the IDEA focuses solely on traditional public schooling. Rhode Island's argument is misrepresented by the majority, which incorrectly frames the issue as one of educational settings or the distinction between traditional and innovative education methods. The state's position emphasizes that the Individuals with Disabilities Education Act (IDEA) focuses explicitly on instruction associated with public preschool, elementary, and secondary education, not on adult education, which is governed by a different statute. The IDEA’s definition of "transition services" outlines a coordinated set of activities for children with disabilities aimed at facilitating their movement from school to post-school activities, which include adult education. However, adult education is classified as a "post-school activity" and cannot simultaneously be considered "school." The majority's assertion that adult education qualifies as a transition service is challenged by statutory interpretation principles, which indicate that limiting clauses modify only the nouns they directly follow. Therefore, the majority's definition of "public education" fails to align with the statutory framework established by Congress, which clearly delineates the boundaries between school education and post-school activities, undermining the assertion that adult education triggers the Free Appropriate Public Education (FAPE) requirement for students in traditional schooling contexts. The Supreme Court emphasizes the need for courts to refrain from imposing their educational preferences on states, as stated in Rowley. The majority's stance diverges from this principle and the broader deference to state authority mandated by the Individuals with Disabilities Education Act (IDEA). The IDEA grants states considerable discretion in establishing educational procedures, underscored by the statutory language that holds states primarily responsible for educating children with disabilities. Congress has consistently permitted states to decide on the provision of Free Appropriate Public Education (FAPE) for disabled students, affirming this through various amendments to the IDEA since its inception in 1975. The majority's interpretation regarding Rhode Island's adult education system may challenge the validity of similar provisions in other states, such as Maine, which limits special education services to students under twenty. This interpretation could lead to significant financial implications for local school systems, potentially compromising services for other students. The majority's assertions about the characteristics of "public education" lack statutory support and misinterpret the definitions provided in the relevant legislation, diverging from both the legal context and established meanings. The Oxford English Dictionary defines "public education" as education provided by the State, emphasizing that "public" refers to being funded and controlled by the public. Similar definitions from the Random House Dictionary illustrate that public schools are maintained at public expense for community education, particularly in primary and secondary schools. However, the majority's interpretation expands these definitions to include any program receiving "significant" public funding, which is criticized as lacking proper justification. Rhode Island's adult education system notably differs from traditional public education. It is not entirely free; enrollees in GED classes typically cover about 20% of the costs, with state assistance available only for certain low-income individuals. The existence of state-funded free testing for some does not equate to the programs being entirely state-funded. Additionally, adult education programs are managed by community-based organizations rather than the state, which does not control their administration, curriculum, or scheduling but merely sets performance targets. This lack of direct state control undermines the argument that these programs qualify as public education under the IDEA's definition of "secondary school." K.L. contends that the administration by non-state entities is irrelevant to the classification, but this point is contested. K.L. highlights that the IDEA defines "secondary school" as a nonprofit institution providing secondary education per state law, and similarly defines "elementary school." Rhode Island law does not classify adult education as either secondary or elementary education. K.L. fails to demonstrate that the level of state oversight for charter and residential schools matches the regulation of adult education. Adult education programs, such as the GED and NEDP, differ significantly from traditional secondary education. The GED program functions as test preparation for the GED exam, while the NEDP pairs students with assessors to award diplomas based on life experience, without requiring classroom attendance. In contrast, Rhode Island's secondary school requirements include demonstrating proficiency in core subjects, completing a minimum number of courses, and undergoing performance assessments, all regulated by the Council on Elementary and Secondary Education. Adult education programs do not adhere to these graduation criteria or the state assessment standards, indicating they do not meet the IDEA's definition of secondary education. K.L. argues that the content differences should not matter since the IDEA does not stipulate specific curricula; however, the IDEA states that curricula are determined by state law. Consequently, Rhode Island's standards for adult education do not align with those for secondary school. The interpretation of "public education" to include adult education programs contradicts long-standing state practices regarding providing a Free Appropriate Public Education (FAPE) to individuals over eighteen, which K.L. believes lacks textual support in the IDEA.