## Facts

- L.I., an elementary student in a Maine public school district, earned strong grades but developed increasing social and emotional difficulties, including withdrawal, anxiety, self-harm, and a decline from high honors to honors.
- After escalating distress, L.I. attempted suicide during sixth grade and later underwent neuropsychological evaluation.
- L.I. was diagnosed with Asperger’s Syndrome and an adjustment disorder with depressed mood; specialists recommended direct social-skills instruction and therapeutic interventions.
- The school district indicated it would provide interim tutoring while evaluating eligibility, but no tutoring was provided, despite parental follow-up.
- L.I.’s parents homeschooled her and then unilaterally placed her at a small private school where she performed above grade level and had some improved peer interactions, though the placement did not provide all recommended specialized services.
- The district’s Pupil Evaluation Team accepted the diagnoses and recognized a need for social-skills and pragmatic language instruction but found L.I. ineligible under the IDEA because the disability did not “adversely affect” her educational performance, given her academic success.
- An IDEA due process hearing upheld the district’s ineligibility determination; the federal district court reversed, found IDEA eligibility, and ordered relief including tuition reimbursement and an appropriate IEP.

## Issues

1. Whether a student with Asperger’s Syndrome and serious emotional/social impairment, but strong academic achievement, qualifies as a “child with a disability” under the IDEA’s requirement that the disability adversely affect educational performance.
2. Whether “educational performance” under the IDEA is limited to grades and test scores or includes social, emotional, and behavioral functioning affecting access to educational benefit.
3. Whether, upon a finding of IDEA eligibility and denial of a FAPE, equitable relief may include reimbursement for a unilateral private placement.

## Decision

- The First Circuit affirmed the judgment that L.I. qualified as a “child with a disability” under the IDEA.
- The court held that “educational performance” is not confined to academic metrics and may include significant social and emotional limitations that impede educational benefit.
- The court concluded the administrative decision rested on an erroneous legal interpretation, reducing any deference owed to the hearing officer on that question.
- The court upheld equitable relief flowing from the IDEA violation, including tuition reimbursement and orders requiring an appropriate program addressing L.I.’s needs.

## Legal Principles

- IDEA eligibility cannot be denied solely because a student earns good grades or tests at/above grade level.
- “Adversely affects educational performance” includes nonacademic effects—social interaction, emotional regulation, communication, and school functioning—that materially interfere with the student’s ability to benefit from education.
- Courts give due weight to administrative factfinding but review statutory interpretation de novo; deference is unwarranted where the administrative decision applies an incorrect legal standard.
- When a district fails to offer an appropriate IEP and denies a FAPE, courts may award equitable reimbursement for a parental private placement reasonably calculated to provide educational benefit, even if the placement is not perfect.

## Conclusion

The First Circuit held that IDEA’s “adverse effect” requirement is satisfied when a disability substantially impairs a student’s social and emotional functioning in school, even if academic performance remains strong, and it affirmed reimbursement-based relief after the district improperly denied eligibility and appropriate services.


Mr. I. v. Me. Sch. Admin. Dist. No. 55, 480 F.3d 1 (1st Cir. 2007)