## Facts

- Illinois elected to participate in the federal early-intervention program for infants and toddlers with disabilities under IDEA Part H (later Part C) and accepted federal funds conditioned on compliance with federal requirements.
- Under the statute’s phased implementation framework, Illinois’s fifth year of participation began December 1, 1992, after which the state was required to operate a statewide system serving all eligible infants and toddlers.
- Plaintiffs (infants and toddlers with developmental delays and their parents/guardians) sued state officials on behalf of a certified class of approximately 26,000 eligible children allegedly not receiving required early-intervention services.
- Plaintiffs alleged statewide failures, including inadequate child-find/identification, untimely or unavailable services, insufficient interagency coordination, and noncompliance with statutory timelines and procedural protections.
- The suit sought declaratory and prospective injunctive relief to bring Illinois’s early-intervention system into compliance, not money damages.
- The case proceeded to cross-motions for summary judgment and requests for injunctive relief.

## Issues

1. Whether Illinois’s participation in IDEA Part H/C and acceptance of federal funds obligated it to provide early-intervention services statewide to all eligible infants and toddlers by the statutory deadline and to maintain required administrative systems.
2. Whether eligible children and their parents could enforce IDEA Part H/C obligations in federal court against state officials to obtain prospective injunctive relief.
3. Whether Illinois’s alleged statewide failure to identify and serve large numbers of eligible children constituted a violation warranting broad injunctive relief.
4. Whether asserted defenses (including non-enforceability, immunity-based arguments, or administrative and resource constraints) barred relief.

## Decision

- Plaintiffs’ motion was granted and defendants’ motion was denied.
- The court found Illinois in violation of IDEA Part H/C for failing to establish and operate a compliant statewide early-intervention system and to ensure services for all eligible infants and toddlers.
- The court entered an injunction requiring state officials to stop violating IDEA Part H/C and to take corrective action to achieve compliance.

## Legal Principles

- When a state voluntarily participates in a federal spending program and accepts funds, it is bound by the program’s substantive and procedural conditions, including time-bound implementation duties.
- IDEA Part H/C imposes enforceable statewide obligations to identify, evaluate, and provide early-intervention services to eligible infants and toddlers once the implementation period has passed.
- Prospective injunctive relief may be obtained against responsible state officials to remedy ongoing violations of federal law.
- Administrative difficulty, funding limits, or workforce shortages do not excuse failure to comply with mandatory federal requirements once the state has elected to participate and accept funds.
- Structural injunctive relief may be appropriate where violations are statewide and systemic rather than isolated.

## Conclusion

The court held that Illinois’s prolonged statewide failure to deliver IDEA Part H/C early-intervention services to eligible infants and toddlers violated federal law and warranted an injunction compelling state officials to take corrective action to bring the system into compliance.


Marie O. v. Edgar, No. 94 C 1471, 1996 U.S. Dist. LEXIS 1070 (N.D. Ill. Feb. 2, 1996)