## Facts

- Wayne Teague, Alabama’s State Superintendent of Education, selected hearing officers to conduct due-process hearings under the Education for All Handicapped Children Act (EAHCA) (now the IDEA).
- Alabama used three-person hearing panels chosen by the superintendent; panel members could be (1) employees or officers of local school systems other than the one the child attended and (2) employees of state institutions of higher education.
- Since late 1979, the typical panel included one university educator and two local school-system employees.
- Lisa Mayson and William Dean Carpenter, disabled students in the Mobile public school system, requested EAHCA due-process hearings regarding disputes about their individualized education programs (IEPs).
- Mayson and Carpenter objected to the panel members selected for their hearings, arguing that Teague’s selection method violated federal impartiality requirements because the officers were tied to public educational agencies and, in some instances, to state special-education policy formation.
- The hearings proceeded with panels selected under Alabama’s method; the panels ruled against the students. Review panels selected in the same manner affirmed the outcomes.
- Mayson and Carpenter sued in federal district court, challenging the legality of Alabama’s hearing-officer selection practices.
- Evidence at trial showed close coordination among Teague and local superintendents to develop and advance shared special-education policies, and that some university personnel used as officers had participated in developing or advising on Alabama special-education policies.
- The district court ruled for the students and enjoined Teague from selecting (1) officers or employees of local school systems the child did not attend and (2) university personnel involved in formulating state policies on educating disabled children as due-process hearing officers.
- Teague appealed; a related case (Parker) raising similar challenges was also before the Eleventh Circuit.

## Issues

1. Whether the EAHCA and its implementing regulations require disqualification of local school-system employees (from districts other than the child’s) from serving as “impartial” due-process hearing or review officers.
2. Whether university employees who participated in formulating state special-education policies may be barred from serving as hearing officers under the EAHCA’s impartiality requirement.
3. Whether the district court’s injunctive relief reflected an overly broad reading of the EAHCA and the regulations governing impartial hearing officers.

## Decision

- The Eleventh Circuit affirmed the district court’s order.
- The court held that the EAHCA’s requirement of an “impartial” hearing officer, including the regulatory bar on hearing officers who are employees of an agency involved in the education or care of the child, supported excluding local school-system employees even when they worked in a district different from the child’s.
- The court also upheld excluding university personnel who had been involved in developing state special-education policies, because their professional roles created a conflict with the neutrality required of EAHCA hearing officers.
- The court rejected Alabama’s narrower interpretation that would disqualify only employees of the child’s own local education agency.
- The court concluded the injunction was supported by the statute, regulations, and prior decisions interpreting the EAHCA’s impartiality protections.

## Legal Principles

- The EAHCA requires a due-process hearing before an “impartial” hearing officer; neutrality is not limited to the absence of proven personal bias and may be defeated by institutional conflicts.
- Implementing regulations bar a hearing officer who is an employee of any agency involved in the education or care of the child and also bar officers with a personal or professional interest that conflicts with objective decisionmaking.
- For EAHCA impartiality, “agency involved in the education or care of the child” may reach beyond the child’s own district where the state’s special-education program is carried out through closely aligned state and local educational entities.
- University personnel may be disqualified when their work ties them to the state’s special-education policy decisions being challenged in due-process proceedings, because that relationship is incompatible with the required neutrality.
- Federal courts may issue injunctive relief limiting who a state may appoint as EAHCA hearing officers to ensure future hearings meet statutory and regulatory impartiality requirements.

## Conclusion

Mayson v. Teague held that Alabama’s practice of staffing EAHCA due-process panels with other-district school employees and university personnel involved in state special-education policymaking failed the Act’s impartiality requirements, and the Eleventh Circuit affirmed injunctive relief barring those categories of individuals from serving as hearing officers.


Mayson v. Teague, 749 F.2d 652 (1984)