## Facts

- Thomas P. was a high-school student in the Richland School District who received special-education services under the Individuals with Disabilities Education Act (IDEA) based on an identified learning disability.
- Thomas participated in the vandalism of two elementary schools in the district.
- The district conducted an IDEA manifestation determination and concluded the vandalism was not a manifestation of Thomas’s learning disability.
- Relying on that determination, the school board voted to expel Thomas.
- Thomas’s mother, Linda P., requested an IDEA due-process hearing before an administrative law judge (ALJ).
- For the hearing, Linda P. retained a clinical psychologist to evaluate Thomas.
- The psychologist diagnosed Thomas with attention deficit disorder (ADD) and persistent depression and testified that these conditions led to Thomas’s involvement in the vandalism.
- The ALJ set aside the expulsion, finding the misconduct was a manifestation of Thomas’s disabilities as shown by the hearing record, including the newly identified ADD and persistent depression.
- The school district filed a federal action seeking reversal, arguing IDEA discipline protections and the manifestation inquiry should be limited to the disability previously identified as the basis for IDEA services (the learning disability), not the later-diagnosed ADD and depression.

## Issues

1. In an IDEA disciplinary challenge, is the manifestation inquiry limited to the student’s disability category previously identified for IDEA eligibility, or may it consider other disabilities shown by the evidence?
2. May an ALJ rely on evaluation evidence and diagnoses developed for the due-process hearing when reviewing whether misconduct was a manifestation of the student’s disability?
3. Did the district establish a basis to overturn the ALJ’s decision setting aside the expulsion?

## Decision

- The court rejected the school district’s argument that IDEA manifestation protections apply only to the student’s previously identified qualifying disability label.
- The court upheld the ALJ’s determination that the manifestation analysis could account for the student’s disabilities as demonstrated by the record, including ADD and persistent depression identified through the hearing process.
- The court affirmed the ALJ’s order setting aside the expulsion and denied the district’s request for reversal.

## Legal Principles

- IDEA discipline protections focus on whether the conduct is a manifestation of the child’s disability-related needs as shown by the record, not only on the single disability category previously used to provide services.
- In an IDEA due-process hearing challenging discipline, the factfinder may consider relevant evaluation evidence and professional diagnoses presented at the hearing, even if those conditions were not previously identified by the school district when it made its initial manifestation decision.
- A school district seeking judicial reversal of an IDEA administrative decision must show the administrative outcome should not stand under the governing standard of review; a district cannot avoid IDEA manifestation limits by treating the student’s disability as confined to a single eligibility label when the record supports additional disability conditions tied to the misconduct.

## Conclusion

The district court left the ALJ’s decision in place because the IDEA’s manifestation framework is not restricted to the student’s earlier eligibility label and permits consideration of disabilities established through the due-process record, including later-identified ADD and persistent depression that the ALJ found were connected to the vandalism that led to the expulsion.


Richland School District v. Linda P. ex rel. Thomas P., 2000 U.S. Dist. LEXIS 15162 (2000)