Schaffer ex rel. Schaffer v. Weast

PETITIONER: Brian Schaffer, a minor, by his parents and next friends, Jocelyn and Martin Schaffer, et ux, et al.
RESPONDENT: Jerry Weast, Superintendent, Montgomery County Public Schools, et al.
LOCATION: Board of Immigration Appeals

DOCKET NO.: 04-698
DECIDED BY: Roberts Court (2005-2006)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 546 US 49 (2005)
GRANTED: Feb 22, 2005
ARGUED: Oct 05, 2005
DECIDED: Nov 14, 2005

ADVOCATES:
David B. Salmons - argued the cause for Respondents
Gregory G. Garre - argued the cause for Respondents
William H. Hurd - argued the cause for Petitioners

Facts of the case

The parents of Brian Schaffer, a disabled child, sued their public school district under the Individuals with Disabilities Education Act (IDEA). Schaffer's parents claimed the Individualized Education Program that the school system devised for their son, and which IDEA required for each disabled student, was inadequate. The district court ruled for the Schaffers, but the Fourth Circuit reversed, holding that the lower court incorrectly assigned the burden of proof to the school system. Because IDEA was silent on whether the parents or the school system bear the burden of proof, the Fourth Circuit held, the general rule that the party initiating the suit bears that burden should be applied.

Question

Do the parents or school system bear the burden of proof in disputes over a child's individualized education program under the Individuals with Disabilities Education Act?

Media for Schaffer ex rel. Schaffer v. Weast

Audio Transcription for Oral Argument - October 05, 2005 in Schaffer ex rel. Schaffer v. Weast

Audio Transcription for Opinion Announcement - November 14, 2005 in Schaffer ex rel. Schaffer v. Weast

John G. Roberts, Jr.:

Justice O'Connor has the opinion in No. 04-698, Schaffer versus Weast.

Sandra Day O'Connor:

This case comes here on writ of certiorari to the Court of Appeals for the 4th Circuit.

In 1970, Congress passed what today is called the Individuals with Disabilities Education Act; the acronym of that is IDEA.

That Act is intended to ensure all disabled children a free, appropriate public education.

It requires public schools to identify disabled children; it establishes procedures for schools and for parents to work together to create an Individualized Education Program, called an IEP, for each disabled child.

If the parents disagree with the school about what services are appropriate, the Act gives the parents the right to request a so-called due-process hearing.

The Act specifies various requirements for these hearings, but it does not specify which party bears the burden of persuasion at the hearing.

In this case, the 4th Circuit Court of Appeals put the burden of persuasion on the parents, concluding that there was no sufficient reason to depart from the usual rule that the burden of persuasion lies with the party seeking relief.

In an opinion filed today with the Clerk of the Court, we affirm that judgment.

We hold that the burden of persuasion in an administrative hearing challenging an IEP is properly placed upon the party seeking relief -- in this case, that’s the parents, the petitioners -- but where a school district initiates a hearing, it will bear the burden of persuasion.

Because the Individuals with Disabilities Act is silent about where the burden of persuasion should lie, we follow the ordinary default rule that plaintiffs bear the burden regarding the essential aspects of their claims.

Although this default rule has exceptions, we only rarely place the entire burden of persuasion at the outset of a proceeding upon the opposing party, as petitioners urge us to do in this case.

Absent some reason to believe that Congress intended otherwise, we conclude that the burden of persuasion lies where it usually does, with the party seeking relief.

Justice Stevens has filed a concurring opinion, and Justice Ginsburg and Justice Breyer have each filed dissenting opinions.