## Facts

- Ryan V.D. was a student in Indiana with dyslexia.
- Ryan’s divorced parents, Linda W. (mother) and Steven V.D. (father), shared joint custody.
- Ryan lived about 75% of the time with his mother within the South Bend School Corporation and about 25% with his father within the Mishawaka School City.
- Ryan received special education services through an individualized education program (IEP) associated with the Mishawaka schools.
- Ryan’s parents believed the IEP and related programming were legally inadequate under the Individuals with Disabilities Education Act (IDEA).
- The dispute proceeded through IDEA administrative processes, including multiple due process hearings and appeals to the Indiana Board of Special Education Appeals (BSEA) within the Indiana Department of Education.
- After the administrative process, the parents filed an IDEA civil action in federal district court seeking review of the administrative decisions, reimbursement/compensation for educational expenses, and attorneys’ fees.
- Defendants (including the Indiana Department of Education and local Mishawaka-related entities) argued that Indiana “legal settlement” rules placed Ryan’s legal settlement in South Bend, so Mishawaka owed no duty to educate Ryan and could not properly be sued under the IDEA.
- Defendants moved to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1) or, in the alternative, for summary judgment under Rule 56.
- Plaintiffs moved to strike defendants’ opening brief for exceeding page limits; defendants sought leave to file an oversized brief.

## Issues

1. Whether the federal district court had subject-matter jurisdiction over the parents’ IDEA action seeking judicial review of final state administrative decisions.
2. Whether defendants were entitled to summary judgment on the ground that Indiana “legal settlement” law made South Bend (not Mishawaka) solely responsible for Ryan’s education, rendering Mishawaka-related defendants improper parties.
3. Whether the court should strike defendants’ overlength brief or instead allow it to be filed.

## Decision

- The court denied the motion to dismiss for lack of subject-matter jurisdiction, holding that the IDEA authorizes a civil action by parties aggrieved by the state administrative findings and decision, and that this statutory review provision supports federal jurisdiction.
- The court denied defendants’ motion for summary judgment, rejecting the argument that Indiana “legal settlement” rules categorically relieved Mishawaka and related entities of responsibility (and thus liability) for Ryan’s IDEA services in the joint-custody, split-residence circumstances presented.
- The court granted defendants leave to file an oversized brief and denied plaintiffs’ motion to strike.

## Legal Principles

- Federal courts have subject-matter jurisdiction over an IDEA civil action brought by a party “aggrieved” by the final decision from the state special-education administrative process; the IDEA’s judicial-review provision supplies a basis for federal adjudication of the challenge.
- A defendant cannot convert a dispute about which agency or district bears responsibility for providing a free appropriate public education (FAPE) into a jurisdictional bar when the plaintiffs’ claim arises under the IDEA and seeks review of IDEA administrative determinations.
- Summary judgment is unavailable where the movant’s state-law responsibility theory does not establish, as a matter of law, that it owed no duty under the IDEA in the circumstances; Indiana “legal settlement” concepts did not, on this record and custody arrangement, foreclose Mishawaka’s responsibility.
- Courts may permit an oversized brief when leave is granted; exceeding page limits without prior leave does not automatically require striking the filing where the court allows it and no sufficient prejudice is shown.

## Conclusion

In *Linda W. v. Indiana Department of Education*, the district court held that it had jurisdiction over the parents’ IDEA suit seeking judicial review and related relief following state administrative proceedings, and it refused to end the case at the pleading or summary-judgment stage based on defendants’ Indiana “legal settlement” argument that only South Bend bore educational responsibility; the court also allowed defendants’ oversized brief and denied the motion to strike.


Linda W. v. Indiana Department of Education, 927 F. Supp. 303 (1996)