Cedar Rapids Community School District v. Garret F., 526 U.S. 66 (1999), was a United States Supreme Court case in which the Court ruled that the related services provision in the Individuals with Disabilities Education Act (IDEA) required public school districts to fund "continuous, one-on-one nursing care for disabled children" despite arguments from the school district concerning the costs of the services."[1]: 6 The judges relied heavily on Irving Independent School Dist. v. Tatro.[2][1] Under the Court's reading of the IDEA's relevant provisions, medical treatments such as suctioning, ventilator checks, catheterization, and others which can be administered by non-physician personnel come within the parameters of the special education law's related services.[3] Disability advocates considered the Court decision to be a "substantial victory for families of children with disabilities."[1]: 6 Amendments were made in the Education Flexibility Partnership Act of 1999 to increase IDEA funding as a result of the case.[1]: 6
| Cedar Rapids Community School District v. Garret F. | |
|---|---|
 | |
| Argued November 4, 1998 Decided March 3, 1999 | |
| Full case name | Cedar Rapids Community School District v. Garret F., a minor, by his mother and next friend, Charlene F. |
| Citations | 526 U.S. 66 (more) 119 S. Ct. 992; 143 L. Ed. 2d 154 |
| Case history | |
| Prior | 106 F.3d 822 (8th Cir. 1997) (affirmed) |
| Holding | |
| The exception for "medical services" from IDEA's related services provision only exempts services which must be provided by a physician. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Stevens, joined by Rehnquist, O'Connor, Scalia, Souter, Ginsburg, Breyer |
| Dissent | Thomas, joined by Kennedy |
| Laws applied | |
| Individuals with Disabilities Education Act | |
Background
editThe Court reasoned in a seven to two decision, that Tatro established the bright-line rule, by which "the services of a physician (other than for diagnostic and evaluation purposes) are subject to the medical services exclusion, but services that can be provided in the school setting by a nurse or qualified layperson are not."[4]
Justices Clarence Thomas and Anthony M. Kennedy dissented, noting that the ruling "blindsides unwary states."[3]
References
edit- ^ a b c d Ian O. Javier, ed. (2005), The Individuals with Disabilities Education Act (IDEA), Nova Science Publishers, Inc. 2013, ISBN 978-1594547102
- ^ Irving Independent School Dist. v. Tatro, 468 U.S. 883 (1984).
- ^ a b "Wrightslaw, article title The Supreme Court of the United States 526 U.S. 66 (1999) Cedar Rapids Community School District v. Garret F., a minor, by his mother and next friend, Charlene F." Retrieved October 6, 2014.
- ^ Cedar Rapids Community School Dist. v. Garret F., 526 U.S. 66, 72 (1999).
External links
edit- Text of Cedar Rapids Community School Dist. v. Garret F., 526 U.S. 66 (1999) is available from: Cornell Google Scholar Justia Library of Congress Oyez (oral argument audio)
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