Loch v. Edwardsville School District No. 7

Citation: 327 F. App'x 647Docket: No. 08-3073

Court: Court of Appeals for the Seventh Circuit; June 19, 2009; Federal Appellate Court

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Thomas and Glenna Loch, along with their daughter Kayla, a public school student with diabetes, filed a lawsuit against Edwardsville School District No. 7, claiming that the district failed to provide Kayla with an appropriate education as required by the Individuals with Disabilities Education Act (IDEA), the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act, Title VI of the Civil Rights Act, and Title IX of the Education Amendments. The district court dismissed several of the Lochs' claims and granted summary judgment in favor of the school district. The Lochs appealed, but the decision was affirmed.

Kayla was diagnosed with type 1 diabetes at age ten, leading to the creation of a 504 plan that allowed accommodations for her condition. However, additional diagnoses of adjustment disorder and social anxiety disorder were made later, with no amendments requested to her 504 plan despite her declining attendance. She stopped attending high school classes during her sophomore year and enrolled at Lewis and Clark Community College without the school’s approval.

The Lochs proposed that Kayla take community college classes while remaining enrolled at the high school, a request the principal could not accommodate under school board guidelines but offered to create an alternative plan. When the Lochs requested an IDEA evaluation for special education eligibility, school officials found no medical basis for her absenteeism, concluding that Kayla's academic performance and psychological functioning were normal and did not warrant special education services. The Lochs contested this decision, seeking a hearing to challenge the eligibility determination and reimbursement for community college tuition, but the hearing officer upheld the district's findings and denied their requests.

The Lochs brought their case to federal district court, which dismissed Thomas and Glenna's claims under the Individuals with Disabilities Education Act (IDEA) due to lack of standing, as Kayla was 18 at the time of filing. The court also dismissed Kayla's claims under the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act, along with her parents' claims under these statutes and Title VI and Title IX, because they had not presented these claims to the hearing officer as required and because relief was available under the IDEA. The court granted summary judgment for the district on Kayla’s Title IX and IDEA claims, determining that she was not covered by the IDEA due to not being disabled and that the district had complied with procedural requirements. The Lochs sought reconsideration of the court's decisions, which was denied. On appeal, they challenged the summary judgment and the dismissal of certain claims, asserting that parents have enforceable rights under the IDEA, but those rights transfer to the student upon reaching majority under Illinois law. The Lochs argued that they should not have to exhaust administrative remedies for their ADA and Title IX claims due to futility, but the court found that exhaustion was necessary since the identified injuries were remediable under the IDEA. The court’s standard for reviewing the summary judgment under IDEA suits is distinct, as it is based on the administrative record rather than new evidence, and the findings can only be reversed if clearly erroneous.

The Lochs contest the district court's finding that Kayla's medical condition does not qualify under the Individuals with Disabilities Education Act (IDEA). Under IDEA, a 'child with a disability' includes those with health impairments needing special education. The Lochs assert that Kayla's anxiety about attending class and her declining grades demonstrate a need for special education. However, evidence shows her grades were satisfactory until her absence in spring 2004, and there is no medical proof linking her anxiety or diabetes to her school attendance issues. Medical reports indicated her health was stable during her absences. Precedents cited support the idea that improved academic performance negates the need for special education. Consequently, the district court correctly determined the Lochs did not prove Kayla required special education. 

Additionally, the Lochs claim entitlement to reimbursement for Kayla's community college tuition, arguing the district failed to provide sufficient notice before withdrawing her from Edwardsville High School. While noncompliance with IDEA procedures can exempt parents from developing an alternate education plan, the Lochs did not demonstrate such failure, as the district provided adequate notice. Thus, the district court did not err in denying their reimbursement claim. The Lochs' motion for reconsideration was also rejected, as the court's summary judgment was deemed proper. Other arguments raised by the Lochs did not warrant further discussion. The decision was affirmed.