Cedar Rapids Community School Dist. v. Garret F.

PETITIONER: Cedar Rapids Community School Dist.
LOCATION: Knowles' Car

DOCKET NO.: 96-1793
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 526 US 66 (1999)
ARGUED: Nov 04, 1998
DECIDED: Mar 03, 1999

Beth S. Brinkmann - On behalf of the United States, as amicus curiae, supporting the respondent
Douglas R. Oelschlaeger - Argued the cause for the respondent
Susan L. Seitz - Argued the cause for the petitioner

Facts of the case

Garret F., a minor and student in Cedar Rapids Community School District, requires a wheelchair and is dependent upon a ventilator. He requires assistance in attending to his physical needs during the school day. The school district declined to accept financial responsibility for Garret's services in order for him to be able to attend school. The school district believed it was not legally obligated to provide one-on-one care. An Administrative Law judge concluded that the Individuals with Disabilities Education Act (IDEA) required the school district to provide "school health services," which are provided by a "qualified school nurse or other qualified person," but not medical services, which are limited to services provided by a physician. The District Court and the Court of Appeals affirmed despite arguments from the school district that such one-on-one care is too costly and too involved to be considered anything but medical in nature.


Do schools that receive federal funding under the Individuals with Disabilities Education Act have to pay for one-on-one nursing assistance for certain of their students with disabilities?

Media for Cedar Rapids Community School Dist. v. Garret F.

Audio Transcription for Oral Argument - November 04, 1998 in Cedar Rapids Community School Dist. v. Garret F.

Audio Transcription for Opinion Announcement - March 03, 1999 in Cedar Rapids Community School Dist. v. Garret F.

William H. Rehnquist:

The opinion of the Court in No. 96-1793, Cedar Rapids Community School District versus Garret F. will be announced by Justice Stevens.

John Paul Stevens:

To help assure that all children with disabilities have available to them, a free, appropriate, public education which emphasizes special education and related services designed to meet their unique needs, The individuals with Disabilities Education Act, often referred to as the IDEA, authorizes federal financial assistance to States that agree to provide such children with special education and "related services."

This case involves the meaning of that term.

Respondent, Garret F., is a student in the Cedar Rapids Community School District.

When he was four years old, his spinal column was severed in a motorcycle accident.

Although paralyzed from the neck down, Garret's mental capacities were unaffected and he attends regular classes at school.

He is able to speak, to control his motorized wheelchair and to operate a computer with a device that responds to head movements.

Garret is, however, ventilator-dependent.

He therefore requires a responsible individual nearby to attend to certain physical needs while he is at school, such as, the suctioning of his tracheotomy tube at least once every six hours and urinary and bladder catheterization once a day.

In 1993, Garret's mother asked the District to accept financial responsibility for the in-school services that Garret requires.

The District denied the request believing that it was not legally obligated to provide continuous one-on-one nursing care.

And in Iowa Department of Education hearing, however, an Administrative Law Judge concluded that the IDEA requires the District to bear the cost of the requested services.

The Federal District Court agreed and the Court of Appeals affirmed based on our decision in the case, decided about 15 years ago called by the name of Tatro.

The Court of Appeals concluded that the requested services are supportive services because Garret cannot attend school unless they are provided and that the services are not excluded as medical services.

The Court explained that services provided by a physician other than for diagnostic and evaluation purposes are subject to the medical services exclusion but services that can be provided by a nurse or qualified layperson are not.

The school district petitioned this Court for certiorari arguing that the nursing care at issue constitutes medical services which are excluded from the IDEA's related services provision.

We granted the District petition but we now affirm.

The IDEA's definition of related services broadly encompasses those supportive services that may be required to assist the child with a disability to benefit from special education.

This general definition is illuminated by a parenthetical phrase listing examples of services that are included within the statute's coverage including medical services if not for diagnostic and evaluation purposes.

Although the IDEA itself does not define medical services, more -- more specifically in Tatro, we concluded that the Secretary of Education had reasonably determined that medical services referred to those that must be performed by a physician and not the school health services.

We referenced the likely cost of the services and the competence of school staff as justifications for drawing a line between physician and other services, but our endorsement of that line was unmistakable.

In this case, the District does not argue that the services at issue considered individually can be excluded from the statute's coverage.

In fact, all of the requested services may be provided confidently by a school nurse or other trained personnel.

Instead, the District proposes a multi-factor but essentially cost-based test to determine the scope of the related services provision.

We acknowledge that the District may have legitimate financial concerns but the District's test is supported by neither the text of the statute nor the regulations we upheld in Tatro and the District does not explain why characteristics such as cost make one service any more medical than another.

Absent an elaboration of the statutory term is plainly more convincing than what we reviewed in Tatro.

There is no reason to depart from settled law.

Indeed, accepting the District's cost-based standard would create tension with the central purposes of the IDEA.

In enacting the statute, Congress intended to open the doors of public education to all qualified children and required participating States to educate -- educate disabled children with non-disabled children whenever possible.

We therefore conclude that the District must fund the related services at issue in order to help guarantee that students like Garret are integrated into the public schools.