## Facts

- Grace Blackmon, a young child with severe developmental disabilities, was eligible for special-education services under the Individuals with Disabilities Education Act (IDEA).
- After participating in a state early-intervention program using conventional therapies, Grace’s parents moved her to an intensive, home-based program associated with the Institutes for the Achievement of Human Potential (IAHP).
- When Grace became eligible for IDEA services at age three, the Springfield R-XII School District evaluated her and proposed an individualized education program (IEP) that placed her in a “reverse mainstream” classroom with related services (speech, occupational, and physical therapy) using conventional methods.
- The parents rejected the proposed IEP, sought IAHP-based services and reimbursement, and requested a due process hearing.
- At the administrative hearing, the parents’ counsel limited the dispute to the substantive appropriateness of the IEP and disclaimed procedural challenges.
- A three-member hearing panel found the district’s IEP appropriate, rejected the IAHP program as an appropriate IDEA program for Grace, and treated procedural objections as waived.
- The parents sued in federal district court, which reversed, found the IEP inadequate, relied on asserted procedural violations, ordered reimbursement, and awarded attorneys’ fees.
- The school district appealed.

## Issues

1. Whether the district’s proposed IEP was reasonably calculated to provide Grace a free appropriate public education (FAPE) under the IDEA.
2. Whether alleged procedural violations could support relief in federal court when the parents expressly waived procedural claims at the administrative due process hearing.
3. Whether the parents were entitled to reimbursement and attorneys’ fees.

## Decision

- The Eighth Circuit reversed the district court and reinstated the administrative hearing panel’s decision for the school district.
- The court held the proposed IEP was reasonably calculated to provide Grace some educational benefit and thus satisfied IDEA’s FAPE requirement.
- The court held the parents waived procedural claims at the due process hearing and could not revive them in federal court.
- The court reversed reimbursement and attorneys’ fees because the parents were not prevailing parties.

## Legal Principles

- Under IDEA, an IEP satisfies FAPE if it is reasonably calculated to enable the child to receive some educational benefit; it need not maximize the child’s potential.
- Courts must give due weight to administrative findings and avoid substituting judicial preferences for educators’ decisions on methodology when the IEP meets IDEA’s substantive standard.
- Procedural defects warrant relief only when they cause loss of educational opportunity or seriously infringe parents’ participation in the IEP process.
- IDEA claims, including procedural objections, generally must be raised and preserved in the administrative process; issues expressly waived are not available for later judicial review.
- Attorneys’ fees under IDEA require prevailing-party status; reversal on the merits defeats a fee award.

## Conclusion

The Eighth Circuit held that the school district’s IEP offered Grace a FAPE because it was reasonably calculated to provide educational benefit, rejected judicial substitution of preferred methodology, enforced waiver of unpursued procedural claims, and reversed reimbursement and attorneys’ fees.


Blackmon v. Springfield R-XII Sch. Dist., 198 F.3d 648 (8th Cir. 1999)