## Facts

- Scott P. was a student with severe cognitive and functional impairments resulting from a brain injury and was eligible for special education under the Individuals with Disabilities Education Act (IDEA).
- Scott’s parents alleged the Carlisle Area School District failed to provide a free appropriate public education (FAPE) by delaying or failing to implement necessary educational programming changes.
- The parents sought residential placement and compensatory education extending past Scott’s twenty-first birthday.
- A local IDEA hearing officer found IDEA violations and ordered (1) residential placement and (2) six months of compensatory education beyond age 21.
- A state administrative appeals panel reversed the residential placement order but affirmed the six-month compensatory education award.
- In federal court, the district challenged compensatory education and the parents challenged the denial of residential placement and raised procedural objections; the district court remanded twice to the appeals panel for clarification and ultimately affirmed the panel.

## Issues

1. Whether the district court’s remands to the state appeals panel violated IDEA’s timeliness/finality requirements.
2. What standard governs a state administrative appeals panel’s review of a local hearing officer’s findings, particularly credibility-based findings.
3. What “due weight” a federal district court must give when the hearing officer and state appeals panel reach different results.
4. Whether IDEA required residential placement to provide Scott a FAPE.
5. Whether compensatory education was available and could extend beyond age 21, and whether six months was appropriate.

## Decision

- The Third Circuit affirmed the district court’s judgment.
- The district court’s remands for clarification did not violate IDEA’s finality requirements because they served meaningful judicial review.
- A state appeals panel may conduct an independent (modified de novo) review but must give reasoned, record-based explanations when departing from a hearing officer’s findings, especially credibility determinations.
- A federal district court must conduct an independent review while giving “due weight” to the administrative proceedings and may credit the better-reasoned administrative decision rather than automatically deferring to the higher-tier body.
- Residential placement was properly denied because the record supported that Scott could receive an appropriate education in a non-residential setting; IDEA does not require a residential program merely because it would be beneficial.
- Compensatory education was properly awarded as an equitable remedy for denial of FAPE, could extend beyond age 21, and the six-month award was upheld.

## Legal Principles

- IDEA permits district courts to remand to state administrative decisionmakers for clarification when necessary to enable meaningful judicial review, without necessarily violating statutory finality objectives.
- In a two-tier IDEA administrative system, the state-level reviewer may reexamine fact and law but must explain departures from the hearing officer with sufficient reasoning grounded in the record, particularly on credibility findings.
- Federal courts reviewing IDEA disputes apply a modified de novo approach: they decide based on the preponderance of the evidence while giving “due weight” to administrative expertise; when administrative levels conflict, weight turns on thoroughness and persuasiveness, not hierarchy alone.
- Residential placement is required only when educationally necessary to provide FAPE; IDEA guarantees an appropriate education in the least restrictive environment, not the optimal program.
- Compensatory education is an equitable remedy to make up for past denial of FAPE and may extend beyond age 21 when needed to cure earlier deprivations.

## Conclusion

The Third Circuit upheld the denial of residential placement and affirmed a six-month compensatory education award extending beyond age 21, while clarifying that remands for clarification can be proper under IDEA and that both state and federal IDEA review must be reasoned, record-based, and calibrated to the quality of competing administrative decisions.


Carlisle Area Sch. Dist. v. Scott P., 62 F.3d 520 (3d Cir. 1995)