## Facts

- Mathew Reid, a 16-year-old student with severe learning disabilities, received special education services from the District of Columbia Public Schools (DCPS) under the Individuals with Disabilities Education Act (IDEA).
- DCPS significantly delayed evaluating Mathew and failed for years to provide appropriate special education services, resulting in a denial of a free appropriate public education (FAPE) for approximately four and one-half years.
- After years of inadequate services, DCPS proposed reducing parts of Mathew’s special education program.
- Mathew’s mother sought an IDEA due process hearing seeking (1) an appropriate placement and (2) compensatory education for the period of FAPE denial.
- The hearing officer found a FAPE denial for about 4.5 years and awarded compensatory education, but calculated it mechanically as “one hour for each day” of denial, totaling 810 hours, without explaining why that measure would remedy the violation.
- The hearing officer’s order also allowed Mathew’s IEP team to reduce or discontinue compensatory services if it decided Mathew no longer needed or was not benefiting from them.
- The district court affirmed the hearing officer’s award on summary judgment for the District.

## Issues

1. Whether an IDEA compensatory education award calculated by a mechanical “hour-per-day” formula, unsupported by reasoning or evidence, is entitled to deference.
2. Whether compensatory education should be determined by a fixed quantitative formula (including an hour-for-hour approach) or by an individualized, qualitative standard.
3. Whether a remedial award may authorize an IEP team to reduce or terminate compensatory education based on its later assessment of need or benefit.

## Decision

- The court of appeals reversed the district court’s judgment for the District and remanded.
- The court held that the hearing officer’s mechanical 810-hour calculation merited no deference because it lacked supporting reasoning and evidentiary grounding.
- The court rejected the parents’ proposed hour-for-hour approach as an equally mechanical method inconsistent with IDEA’s remedial purpose.
- The court held that compensatory education must be determined by an individualized assessment aimed at correcting the educational harm caused by the FAPE denial.
- The court invalidated the provision delegating authority to the IEP team to reduce or terminate the compensatory award, concluding the delegation violated IDEA.

## Legal Principles

- Courts and hearing officers may award compensatory education under IDEA as “appropriate” relief to replace educational services a child should have received.
- Compensatory education is not properly computed by rigid formulas; the inquiry is fact-specific and tied to the student’s individual educational deficits and needs.
- The proper objective is to place the child in the position the child would have occupied but for the IDEA violation.
- A remedial award may not allow a school system’s IEP team to unilaterally curtail or end compensatory education that has been adjudicated as a remedy for the system’s own violation.

## Conclusion

The D.C. Circuit required that IDEA compensatory education be crafted through an individualized, qualitative assessment aimed at restoring the student’s educational position absent the FAPE denial, and it barred delegating to an IEP team the power to reduce or terminate an adjudicated compensatory education remedy.


Reid v. District of Columbia, 401 F.3d 516 (D.C. Cir. 2005)