## Facts

- John Doe, Jr., a public-school student in Darien, Connecticut, attended regular classes and a gifted program from kindergarten through fifth grade, with satisfactory or above-average grades and achievement-test results.
- Teachers reported some behavioral and emotional difficulties, including episodes of aggression, but his academic performance remained strong during that period.
- In sixth grade (January 1987), Doe’s emotional condition deteriorated significantly; his parents had him hospitalized and then placed him in a private residential treatment facility (the Grove School), where he received psychotherapy and structured programming.
- The parents requested that the school district classify Doe as eligible for special education under Connecticut law and the federal Education of All Handicapped Children Act (EAHCA) and fund the residential placement and related services.
- The local board denied the request, and a state-appointed hearing officer conducted a four-day due-process hearing in March–April 1988.
- The hearing officer determined Doe was not an “exceptional child” under Connecticut law and not a “handicapped child” needing special education under the EAHCA, finding insufficient adverse effect on educational performance requiring special education.
- The parents filed a federal civil action appealing the administrative decision, alleging legal error, denial of a free appropriate public education (FAPE), procedural unfairness, and seeking declaratory relief and reimbursement.

## Issues

1. Whether a student with serious emotional and behavioral problems, but satisfactory academic performance, qualifies as a child with a disability who “needs special education and related services” under the EAHCA and as an “exceptional child” under Connecticut law.
2. Whether eligibility requires that the condition adversely affect educational performance in a way that creates a need for specially designed instruction.
3. What deference a federal court must give to the state administrative hearing officer’s findings in an EAHCA administrative appeal.
4. If the student were eligible, whether the parents could obtain reimbursement for a unilateral residential placement.

## Decision

- The district court affirmed the hearing officer’s determination that Doe was not eligible for special education under the EAHCA or Connecticut law.
- The court held the record supported the conclusion that Doe’s emotional and behavioral problems did not adversely affect his educational performance to the extent that he required special education.
- The court rejected the parents’ claims of improper or prejudicial conduct by the hearing officer and found no due process violation.
- Because Doe was not eligible under the statute, the court denied declaratory and injunctive relief and denied reimbursement for the Grove School residential placement and related services.

## Legal Principles

- Eligibility under the EAHCA/IDEA depends not only on the presence of a listed disability category (including emotional disturbance), but on whether, by reason of that condition, the student needs special education and related services.
- Emotional or behavioral difficulties alone do not establish eligibility; there must be an adverse impact on educational performance sufficient to require specially designed instruction.
- Evidence of consistent academic success (including grades and standardized test results) may support a finding that a student’s condition has not adversely affected educational performance in the manner required for special education eligibility.
- The EAHCA/IDEA is an education statute; it does not obligate school districts to fund placements that are primarily therapeutic unless educationally necessary to provide FAPE within the statute’s scope.
- In administrative appeals under the EAHCA/IDEA, the district court reviews the record and gives due weight to the state hearing officer’s supported findings and conclusions.

## Conclusion

The court upheld the administrative ruling that a student’s serious emotional difficulties did not trigger EAHCA/IDEA eligibility where his educational performance remained satisfactory and did not show a need for special education, and it therefore denied reimbursement for a parent-selected residential treatment placement.


Doe ex rel. Doe v. Bd. of Educ. of State of Conn., 753 F. Supp. 65 (D. Conn. 1990)