## Facts

- Garret F. was paralyzed from the neck down after a childhood accident; his cognitive abilities were unaffected.
- He attended regular classes in a public school district and performed successfully academically.
- Garret was ventilator dependent and required a responsible person nearby during the school day to address ongoing health needs.
- His in-school needs included urinary catheterization, tracheostomy suctioning, and monitoring for respiratory distress.
- For years, Garret’s family privately funded in-school care, including a licensed practical nurse.
- After those funds ended, Garret’s mother requested that the district fund the in-school nursing/health services necessary for him to attend school safely.
- The district refused, asserting it had no duty to provide continuous one-on-one nursing services.
- An ALJ, the federal district court, and the Eighth Circuit ruled that IDEA required the district to provide and fund the services.

## Issues

1. Whether IDEA’s “related services” requirement obligates a public school district to provide continuous, one-on-one nursing services during the school day to a ventilator-dependent student.
2. Whether such services are excluded from IDEA coverage as “medical services” when they do not require a physician to perform them.

## Decision

- The Supreme Court affirmed the Eighth Circuit in a 7–2 decision.
- The Court held that IDEA required the district to provide the nursing services Garret needed during school hours.
- Applying *Irving Indep. Sch. Dist. v. Tatro*, the Court concluded the services were not excluded “medical services” because they did not have to be provided by a physician.
- The Court rejected the district’s proposed limits based on the services’ continuous nature or expense.

## Legal Principles

- IDEA “related services” include supportive services required to assist a child with a disability to benefit from special education.
- Under *Tatro*’s bright-line rule, the “medical services” exclusion applies only to services that must be performed by a physician (other than diagnostic or evaluation services).
- If a service is necessary for a student to attend school and can be performed by a nurse or other qualified person, the service is a required “related service,” even if it is continuous or costly.
- Cost and administrative burden do not alter the statutory classification of a service as covered “school health services” versus excluded physician-provided “medical services.”

## Conclusion

The Court held that IDEA required the school district to fund and provide in-school nursing services necessary for Garret to attend and benefit from special education because the services were supportive “related services” and were not excluded as “medical services” requiring a physician.


Cedar Rapids Cmty. Sch. Dist. v. Garret F., 526 U.S. 66 (1999)