The Supreme Court Decisions in Special Education

Sixteen Supreme Court decisions, organized around the eleven questions administrators actually get asked. For each case, attorney Julie J. Weatherly gives you the holding, the "What Happened After?" backstory, and the practical takeaway — including the 2023 Perez and 2025 A.J.T. v. Osseo money-damages rulings.

The IDEA tells you what to do. It doesn’t tell you what the words mean.

"Appropriate." "Related services." "Stay-put." "Reasonably calculated." The statute uses those terms — the Supreme Court is what defined them. Over four decades, sixteen decisions have set the boundaries every IEP team, 504 coordinator, and special education administrator works inside, and most of what matters is not in the statute at all. It’s in the holdings, and in what the lower courts and Congress did next.

The Supreme Court Decisions in Special Education: What Did We Learn from Them That the Law Didn’t Tell Us? is a 6-page laminated quick-reference guide by attorney Julie J. Weatherly, Esq. of Resolutions in Special Education, Inc. — one of the most sought-after speakers and trainers in special education law. She organizes the entire body of Supreme Court case law around eleven questions school leaders actually ask, then answers each one with the cases that decided it.

What sets this guide apart is the "What Happened After?" analysis that follows each decision. Knowing that Smith v. Robinson denied parents attorneys’ fees is only half the story — Congress overturned it two years later with the Handicapped Children’s Protection Act, and that single reversal is why due process hearings became the formal, adversarial, attorney-driven proceedings they are today. Weatherly traces that chain for every case, so you understand not just the ruling but the practice it produced.

Fully current through the Court’s most recent special education rulings, including Perez v. Sturgis Public Schools (2023) and A.J.T. v. Osseo Area Schools (2025) — the decision that removed the "bad faith or gross misjudgment" hurdle for ADA/Section 504 money damages claims and materially changed the litigation-risk picture for public school systems nationwide.

Laminated for durability and built to be kept where decisions get made — on the desk, in the IEP meeting, in the due process binder. Not a textbook to read once, but a reference you reach for the moment a question comes up.

What’s Inside

The FAPE standard — what "appropriate" actually requires

• Board of Educ. of the Hendrick Hudson Cent. Sch. Dist. v. Rowley (1982) — the "basic floor of opportunity" standard and the two-question test courts still apply
• Endrew F. v. Douglas Co. Sch. Dist. (2017) — the rejection of "merely more than de minimis" and the "progress appropriate in light of the child’s circumstances" standard

Related services — where "educational" ends and "medical" begins

• Irving Indep. Sch. Dist. v. Tatro (1984) — the origin of the Bright-Line Rule for school health services
• Cedar Rapids Comm. Sch. Dist. v. Garret F. (1999) — why cost alone cannot make a service "medical," and continuous one-on-one nursing care

Attorneys’ fees and expert costs

• Smith v. Robinson (1984) — and the 1986 congressional reversal that reshaped due process
• Arlington Cent. Sch. Dist. v. Murphy (2006) — why expert witness and consultant fees are not recoverable, and the Spending Clause reasoning behind it

Unilateral private school placement and tuition reimbursement

• School Comm. of the Town of Burlington v. Dept. of Educ. (1985) — reimbursement as equitable relief, not damages
• Florence Co. Sch. Dist. Four v. Carter (1993) — reimbursement even for a private school that isn’t state-approved
• Forest Grove Sch. Dist. v. T.A. (2009) — reimbursement when the student never previously received special education services
• Plus the 1997 IDEA Amendments’ equitable provisions — the four grounds on which reimbursement can be reduced or denied

Discipline and the stay-put provision

• Honig v. Doe (1988) — no "dangerousness" exception, the permitted interim measures, and the direct line to today’s 10-day rule, manifestation determination, and 45-day special circumstances removals

Church-state questions in private placement

• Zobrest v. Catalina Foothills Sch. Dist. (1993) — a district employee serving a student in a sectarian school, and the Establishment Clause

Due process procedure

• Schaffer v. Weast (2005) — who carries the burden of persuasion, and why you must still check your own state law
• Winkelman v. Parma City Sch. Dist. (2007) — nonlawyer parents in federal court, and districts’ fee recovery against improper filings

Exhaustion, Section 504/ADA overlap, and money damages

• Fry v. Napoleon Comm. Schs. (2017) — the two-question "gravamen" test for when exhaustion is required
• Perez v. Sturgis Pub. Schs. (2023) — no exhaustion needed for relief the IDEA cannot provide
• A.J.T. v. Osseo Area Schs. (2025) — no heightened "bad faith or gross misjudgment" showing for ADA/Section 504 damages claims

Who It’s For

• Directors and coordinators of special education
• Building principals and assistant principals
• Section 504 coordinators and compliance officers
• Case managers, IEP team chairs, and special education teachers
• School attorneys, advocates, and hearing officers wanting a fast refresher
• University special education law courses and administrator preparation programs
• New administrators inheriting an active due process caseload

Also Available from CASE & Julie J. Weatherly

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