## Facts

- R.B., a minor with Down syndrome and significant health-related needs, attended Mastery Charter School and received special-education services under an IEP.
- R.B.’s medical conditions caused frequent absences; Mastery had previously accommodated her needs by modifying her schedule and not strictly enforcing attendance tracking.
- A dispute arose between R.B.’s parent and Mastery, including Mastery barring the parent from entering the school to assist R.B., which impeded attendance.
- After the parent initiated administrative action, Mastery began marking absences as unexcused under Pennsylvania attendance rules and unilaterally disenrolled R.B. based on consecutive absences.
- Disenrollment terminated R.B.’s access to IEP implementation and special-education services at Mastery, and no alternative placement was affirmatively arranged.
- A hearing officer concluded stay-put did not require continued enrollment; the parent sought a mandatory preliminary injunction in federal court under IDEA’s stay-put provision to compel reinstatement.

## Issues

1. Whether Mastery’s unilateral disenrollment of a student with a disability for absenteeism constituted a “change in educational placement” under the IDEA.
2. If so, whether IDEA’s stay-put provision required R.B.’s reinstatement and continued IEP implementation during the pendency of the dispute.

## Decision

- The court held that Mastery’s disenrollment of R.B. was a change in educational placement under the IDEA.
- The court held that Mastery violated IDEA’s stay-put provision by unilaterally terminating R.B.’s placement and services during an ongoing dispute.
- The court granted a mandatory stay-put injunction ordering Mastery to immediately reinstate R.B. and continue providing her educational program and services pending resolution of proceedings.

## Legal Principles

- IDEA’s stay-put provision (20 U.S.C. § 1415(j)) functions as an automatic injunction that maintains a child’s then-current educational placement during administrative and judicial review.
- A school action that terminates access to a student’s IEP services and FAPE is a fundamental change in educational placement, even if framed as attendance enforcement or administrative status.
- A charter school acting as the student’s local educational agency bears responsibility for implementing the student’s IDEA program and cannot avoid stay-put obligations by disenrolling the student or shifting responsibility to the school district.
- Stay-put cannot be defeated by an agency’s argument that no operative placement exists when the agency itself created that condition through unilateral exclusion.

## Conclusion

The court ordered stay-put reinstatement because disenrollment for absenteeism ended R.B.’s IEP services and materially altered her educational placement, triggering IDEA’s requirement that her existing placement and program be maintained while the dispute was litigated.


R.B. v. Mastery Charter Sch., 762 F. Supp. 2d 745 (E.D. Pa. 2010)