## Facts

- Leah Z., a minor student in Richardson Independent School District (RISD), had multiple diagnosed disabilities and received special education under the IDEA through ARD Committee-developed IEPs.
- By eighth grade, Leah was placed in a Behavior Adjustment class; testing showed significant academic delays and escalating behavioral problems, including regression before ninth grade.
- On a psychiatrist’s recommendation, Leah’s parents unilaterally placed her in a private residential psychiatric facility that provided therapeutic services and on-site schooling.
- Leah showed some academic and behavioral improvement in the residential setting.
- The parents sought reimbursement from RISD, asserting the district failed to provide a FAPE and that residential placement was required for Leah to benefit educationally.
- RISD denied reimbursement, contending it could provide FAPE in-district under an updated IEP and placement.

## Issues

1. Whether RISD’s proposed IEPs and placement were reasonably calculated to provide Leah a FAPE under the IDEA.
2. Whether the private residential placement was educationally necessary (rather than primarily medical, social, or emotional) so as to permit reimbursement for a unilateral placement.
3. What level of “due weight” the district court was required to give the administrative hearing officer’s findings when reviewing the IDEA dispute.
4. Whether the district court’s reimbursement and attorneys’ fees award was proper given the governing standards.

## Decision

- The Fifth Circuit vacated the district court’s judgment and remanded for further proceedings.
- The court held that the district court did not correctly apply the controlling standards for evaluating FAPE and reimbursement for a unilateral residential placement.
- Because the merits required reconsideration, the reimbursement and attorneys’ fees award (total relief of $91,482.60) was also disturbed and had to be reconsidered on remand.

## Legal Principles

- A district provides a FAPE by offering an IEP reasonably calculated to confer meaningful educational benefit; the IDEA does not require maximizing a child’s potential.
- In the Fifth Circuit, whether an IEP is reasonably calculated to provide meaningful educational benefit is evaluated using four factors: (1) individualization based on assessment and performance, (2) least restrictive environment, (3) coordinated and collaborative provision by key participants, and (4) demonstrated academic and non-academic benefits.
- Residential placement is reimbursable only when necessary for the child to receive meaningful educational benefit; a district is not required to fund a placement aimed at medical, social, or emotional problems that are separable from the learning process.
- Evidence that a child performed better in a residential setting does not, by itself, prove the district’s proposed public placement was inappropriate.
- IDEA judicial review is “virtually de novo,” but courts must give due weight to the administrative process; legal conclusions are reviewed de novo and factual findings for clear error.

## Conclusion

The Fifth Circuit required the district court to reassess, under the correct IDEA standards, whether RISD offered Leah a FAPE and whether the residential placement was educationally necessary, vacating the reimbursement and fee awards and remanding for additional findings.


Richardson Indep. Sch. Dist. v. Michael Z. ex rel. Leah Z., 580 F.3d 286 (5th Cir. 2009)