## Facts

- Child Doe, a student with autism and significant intellectual deficits, attended school in a public school district and received special-education services through an individualized education program (IEP) that included a behavior intervention plan (BIP).
- Doe’s parent actively participated in the IEP process, attending nearly all meetings and frequently communicating with school personnel about programming and services.
- The IEP and BIP were revised over time based on evaluations and updated academic and behavioral information; the parent disputed parts of the program, including the use of sensory-integration techniques and other methods she viewed as unsupported.
- During the relevant period (roughly late 2013 to late 2014), school data showed Doe remained far below grade level but made documented academic progress given her disabilities.
- The parent filed an IDEA due-process complaint alleging denial of a free appropriate public education (FAPE); after an extensive administrative hearing, the hearing officer credited the district’s consultant and found no denial of FAPE.
- The parent then sought judicial review and asserted additional federal claims (including under § 1983, § 504, and the ADA) and state-law claims; the district court affirmed the administrative decision, entered summary judgment on remaining federal claims, declined supplemental jurisdiction over state claims, and denied requested filing extensions.

## Issues

1. Whether the school district denied Child Doe a FAPE under the IDEA during the relevant period.
2. Whether the district court abused its discretion by denying extensions of time and leave to file a late summary-judgment response.
3. Whether certain non-IDEA federal claims were barred for failure to exhaust IDEA administrative remedies.
4. Whether a § 504 retaliation claim premised on an alleged IDEA violation could proceed after a no-FAPE-violation determination.

## Decision

- The court of appeals affirmed the judgment in full.
- It held the IEP was reasonably calculated to enable progress appropriate in light of Doe’s circumstances and therefore did not deny FAPE.
- It upheld the district court’s management of deadlines and denial of motions to extend time or accept an untimely summary-judgment response.
- It agreed that certain federal claims were barred because they sought relief for educational harms addressed by IDEA and were not properly exhausted through IDEA procedures.
- It held the parent’s § 504 retaliation theory failed to the extent it depended on proving an IDEA violation.

## Legal Principles

- An IEP satisfies IDEA when it is reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.
- Courts reviewing IDEA disputes must give due weight to administrative findings, including credibility determinations, and may not substitute judicial views of educational policy for those of school authorities.
- Meaningful parental participation is satisfied where the parent is informed, invited, and able to contribute, even if the school does not adopt all parental requests.
- IDEA does not require any particular educational methodology; methodology disputes generally do not establish a FAPE violation if the program as a whole is reasonably calculated to provide appropriate progress.
- Claims whose gravamen is denial of a FAPE, even if pleaded under § 1983, the ADA, or § 504, generally require exhaustion of IDEA administrative procedures.
- A retaliation claim premised on an alleged IDEA violation cannot succeed where no underlying IDEA violation is shown.

## Conclusion

The Eighth Circuit concluded that the district’s IEP and BIP provided appropriate educational benefit under the IDEA’s progress-based standard, deferred to the hearing officer’s credibility findings, enforced IDEA exhaustion limits on related federal claims, and rejected a retaliation claim that depended on proving an IDEA violation.


Albright v. Mountain Home Sch. Dist., 926 F.3d 942 (8th Cir. 2019)