Forest Grove School District v. T. A.
Forest Grove School District v. T.A. is a 2009 Supreme Court case about whether a family can be paid back by a public school district for private special education. The Court said that under the Individuals with Disabilities Education Act (IDEA), parents can receive reimbursement if the public school failed to provide a free appropriate public education (FAPE) and the private school placement is appropriate, even if the child had not previously received special education services from the public school.
What happened: T.A. attended Forest Grove public schools in Oregon from kindergarten through early junior year. In 2003 he was diagnosed with ADHD and other learning disabilities, but the school said he did not qualify for special education. The family then enrolled him in a private school that serves students with special needs.
The Supreme Court decision: The Court, with Justice Stevens writing for the majority, held that IDEA does allow reimbursement for private special education in this situation, and the case was sent back to determine on remand whether the family should receive reimbursement.
Dissent: Justice Souter wrote a dissent, joined by Justices Scalia and Thomas, arguing that Burlington v. Department of Education of Massachusetts should control and that IDEA does not allow reimbursement if a public school has offered FAPE.
After the ruling: In December 2009, a district judge in Oregon ruled that the family was not eligible for reimbursement, saying that the behavior problems and drug use cited for private placement were not disabilities covered by IDEA, and that ADHD had not been listed on the private school application. The Ninth Circuit upheld this decision in 2011, and the Supreme Court denied further review in 2012.
This page was last edited on 3 February 2026, at 20:32 (CET).