## Facts

- Lauren Manecke, a student with significant disabilities (including epilepsy and mental and emotional impairments), attended public high school with special-education support.
- After a serious incident involving her leaving home for several days, her parents withdrew her from public school and placed her in a small private school.
- The parents requested that the school board place her in a public special-education school; the board developed an Individualized Education Program (IEP) and placed her at Nina Harris School for exceptional children.
- Lauren functioned satisfactorily at the public special-education school, while severe conflict persisted in the home environment.
- Believing residential placement was necessary, the parents requested an impartial due process hearing under the Education of the Handicapped Act (EHA); no due process hearing was convened.
- After an unsuccessful informal meeting, the parents unilaterally enrolled Lauren in an out-of-state residential facility at their own expense.
- The parents sought reimbursement and related relief, alleging the board’s failure to provide residential placement and to provide a timely impartial hearing.

## Issues

1. Whether the failure to convene an impartial due process hearing and refusal to fund a residential placement supported damages or reimbursement under § 504 of the Rehabilitation Act.
2. Whether 42 U.S.C. § 1983 could be used to obtain damages or reimbursement for alleged EHA procedural violations.
3. Whether the EHA required the school board to fund a residential placement (and reimburse unilateral placement) where the student was receiving educational benefit from a day special-education program, but had serious problems at home.
4. What remedy, if any, was available for the board’s failure to provide the requested EHA due process hearing.

## Decision

- The Eleventh Circuit affirmed dismissal of the § 504 claim seeking damages or expanded relief for what was, in substance, an EHA dispute.
- The court agreed that § 1983 was not available as an independent damages vehicle to enforce alleged EHA violations where Congress provided a detailed EHA enforcement scheme.
- On the EHA claim, the court largely affirmed the determination that the board was not required to fund the residential placement as an educational necessity on the record presented.
- The court found a procedural violation because the board failed to convene the requested impartial due process hearing.
- The judgment was affirmed in part, reversed in part, and remanded for further proceedings consistent with the opinion regarding the procedural failure.

## Legal Principles

- Under the EHA, a school district must provide a free appropriate public education through an IEP reasonably calculated to confer educational benefit; the statute targets educational needs rather than correcting home or family dysfunction.
- Residential placement is required at public expense only when it is necessary for the child to benefit from special education; it is not required when sought primarily for non-educational reasons (such as addressing home-based behavioral or family conflict) and the child is benefiting educationally from a day program.
- The EHA’s procedural safeguards include a parental right to an impartial due process hearing when disputing identification, evaluation, or placement; failure to provide the hearing is a statutory procedural violation.
- Not every EHA procedural violation warrants reimbursement; relief generally depends on showing loss of educational opportunity or serious interference with parental participation in educational decisionmaking.
- § 504 and § 1983 may not be used to enlarge remedies or obtain damages for disputes fundamentally governed by the EHA’s specific administrative and judicial review framework.

## Conclusion

The court held that the EHA did not require public funding of a residential placement where the student was receiving adequate educational benefit in a day special-education setting and the residential request primarily addressed home-related problems, while also recognizing that the school board violated the EHA by failing to provide the requested impartial due process hearing and remanding for proceedings to address that procedural failure.


Manecke v. Sch. Bd. of Pinellas Cnty., Fla., 762 F.2d 912 (11th Cir. 1985)