## Facts

- S.G., a minor student, lived with foster parents since infancy and previously performed well in school.
- In fifth and sixth grade, S.G. developed severe symptoms, including violent and sexual writings, urinary accidents, and auditory hallucinations instructing self-harm.
- S.G. was repeatedly hospitalized and diagnosed with schizophrenia.
- The school provided informal accommodations (e.g., extended time, reduced workload, class notes, and a pass to leave class when hearing voices) but did not develop an Individualized Education Program (IEP).
- S.G.’s school functioning declined, including missed classes and incomplete assignments.
- At an IEP team meeting, the team agreed S.G. met the IDEA category of “emotional disturbance,” but concluded she did not need special education because her condition did not sufficiently “adversely” affect educational performance.

## Issues

1. Whether schizophrenia may qualify a student for IDEA eligibility under the “emotional disturbance” category when the regulatory criteria are met.
2. Whether S.G.’s condition adversely affected educational performance enough to trigger the duty to provide special education and related services through an IEP.
3. Whether the district court properly gave due weight to the ALJ’s findings when affirming the administrative decision.

## Decision

- The ALJ found S.G.’s schizophrenia caused an adverse educational impact and that the Board violated the IDEA by failing to identify her as a child needing special education and by failing to provide an IEP.
- The ALJ ordered the Board to develop an IEP and provide an appropriate placement; the Board implemented an IEP and placed S.G. in a therapeutic school, where she improved academically.
- The federal district court affirmed the ALJ’s decision.
- The Fourth Circuit affirmed the district court, rejecting the Board’s challenges to IDEA eligibility, adverse educational impact, and the ALJ’s factfinding.

## Legal Principles

- IDEA “emotional disturbance” eligibility is determined by functional, symptom-based criteria; a diagnostic label such as schizophrenia is not categorically excluded if the regulatory characteristics are satisfied and adversely affect educational performance.
- “Adverse educational impact” may be shown by substantial interference with attendance, participation, completion of work, and access to instruction; it does not require total academic failure.
- In IDEA judicial review, administrative factfinding is given “due weight” and treated as prima facie correct; the party challenging the administrative decision bears the burden of persuasion under a preponderance-of-the-evidence standard.

## Conclusion

The Fourth Circuit upheld administrative and district court findings that S.G.’s schizophrenia fit within IDEA’s emotional disturbance criteria and materially impaired her educational functioning, requiring an IEP and appropriate therapeutic placement, and it deferred to well-supported ALJ determinations under the IDEA review framework.


Bd. of Educ. of Montgomery Cnty., Md. v. S.G., 230 F. App’x 330 (4th Cir. 2007)