## Facts

- A.B. was a student with specific learning disabilities affecting reading and writing.
- After attending private school, A.B. enrolled in Anne Arundel County Public Schools (AACPS), where the parties disputed appropriate special-education services under the Individuals with Disabilities Education Act (IDEA).
- AACPS developed IEPs for the 2000–2001 and 2001–2002 school years that placed A.B. primarily in regular education with about 10 hours per week of special-education support and related adjustments based on evaluations.
- A.B.’s mother (D.B.) believed A.B. required full-time special education and unilaterally placed him at a private school for students with learning disabilities (Summit School), then sought public reimbursement.
- An administrative law judge (ALJ) found AACPS’s IEPs were reasonably calculated to provide A.B. a free appropriate public education (FAPE).
- The district court reversed the ALJ, found a denial of FAPE, and ordered AACPS to reimburse two years of private-school tuition.
- AACPS and the superintendent appealed.

## Issues

1. Whether AACPS’s IEPs for the 2000–2001 and 2001–2002 school years were reasonably calculated to provide A.B. a FAPE under IDEA.
2. Whether the district court erred by overturning the ALJ’s decision and ordering reimbursement for unilateral private placement.

## Decision

- The Fourth Circuit reversed the district court and remanded with instructions to enter summary judgment for AACPS and the superintendent.
- The court held AACPS’s IEPs met IDEA’s FAPE requirement because they were reasonably calculated to confer some educational benefit.
- The court concluded the district court failed to give due weight to the ALJ’s findings and impermissibly reweighed educational evidence.
- The reimbursement order for private-school tuition was vacated because AACPS offered a FAPE, foreclosing reimbursement.

## Legal Principles

- Under IDEA, a FAPE requires an IEP reasonably calculated to enable the child to receive some educational benefit, not an education that maximizes the child’s potential.
- Courts reviewing IDEA disputes must give due weight to administrative proceedings and may not substitute their own educational policy judgments for those of school authorities.
- A district court’s “modified de novo” review does not permit rejecting an ALJ’s findings without a record-based explanation.
- Parents who unilaterally place a child in private school may obtain tuition reimbursement only if the public school failed to offer a FAPE (and the private placement is appropriate).

## Conclusion

The Fourth Circuit held AACPS complied with IDEA by offering IEPs reasonably calculated to provide A.B. educational benefit, required deference to the ALJ’s determination, and barred tuition reimbursement because a FAPE was offered.


A.B. ex rel. D.B. v. Lawson, 354 F.3d 315 (4th Cir. 2004)