Narrative Opinion Summary
This case involves an appeal by the Riverside Local School District (RLSD) concerning the designation of financial responsibility for the educational costs of a dependent child, D.B., following a decision by the Juvenile Division of the Auglaize County Common Pleas Court. D.B., who was placed in the custody of Sarah and Michael McFarlin, resided within the RLSD area after being removed from his parents' care. The RLSD challenged the trial court's designation of it as the financially responsible district, arguing that the Minster Local School District or the Fort Loramie Local School District should bear this responsibility based on the child's living arrangements and special education needs. The appeal highlighted procedural omissions and inaccuracies in applying statutory criteria under R.C. 2151.362 and R.C. 3313.64, which govern the determination of financial responsibility for educational costs. The appellate court found that the trial court had not adequately considered the statutory requirements, particularly the necessity to identify the responsible district based on the child's or parents' residence at the relevant times. The judgment was reversed and remanded for an evidentiary hearing to properly apply these criteria and ascertain the correct financially responsible school district. Costs were assigned to the appellant due to the absence of a party opponent in this appeal.
Legal Issues Addressed
Application of R.C. 2151.362 in Juvenile Court Proceedingssubscribe to see similar legal issues
Application: The case was remanded for further proceedings to ascertain the appropriate school district responsible for the child's educational costs as outlined by R.C. 2151.362.
Reasoning: Consequently, the case is remanded for an evidentiary hearing to ascertain whether R.C. 3313.64(C)(1) or (2) applies, focusing on D.B.'s educational needs.
Criteria for Determining School District Responsibility under R.C. 3313.64subscribe to see similar legal issues
Application: The appellate court found the trial court's reliance on the residence of the legal custodians insufficient for determining financial responsibility.
Reasoning: The appellate review indicated that R.C. 3313.64(C) does not support determining financial responsibility based solely on the legal custodians' residence.
Designation of Financially Responsible School Districtsubscribe to see similar legal issues
Application: The court failed to designate the financially responsible school district when legal custody of the child was awarded, which was later rectified on appeal.
Reasoning: In this case, the court issued a judgment on July 20, 2020, granting legal custody of D.B. to the McFarlins but failed to designate the financially responsible school district.
Responsibility of School Districts for Special Educationsubscribe to see similar legal issues
Application: The court must consider the need for special education and determine the responsible district based on the last known residence of the child's parents.
Reasoning: If special education is needed, the school district of residence, defined in R.C. 3323.01, is obligated to pay tuition.