## Facts

- Edward P. Springer attended Fairfax County public schools in regular education and generally earned average or above-average grades, advancing grade to grade without special education services.
- He maintained satisfactory relationships with teachers and peers and participated in extracurricular activities (including church group, Boy Scouts, and school athletics).
- In eleventh grade, his behavior deteriorated, including juvenile delinquency and repeated rule violations (e.g., theft from parents, substance use, truancy, fighting, leaving campus without permission, and other misconduct).
- His academic problems coincided with absenteeism; he missed final exams, failed three of seven classes, and was not promoted.
- Edward’s parents unilaterally placed him in a private school and sought IDEA special education eligibility and tuition reimbursement, asserting he had a “serious emotional disturbance” (SED).
- Multiple psychological evaluations concluded Edward was not seriously emotionally disturbed.
- A local hearing officer found Edward IDEA-eligible as emotionally disturbed, relying almost entirely on a psychiatrist’s letter prepared for juvenile court proceedings.
- On administrative appeal, the State Review Officer (SRO) reversed, finding Edward socially maladjusted with a conduct disorder, but not SED under IDEA regulations.
- The district court upheld the SRO; the parents appealed.

## Issues

1. Whether Edward’s delinquency, conduct disorder, and related behavior constituted a “serious emotional disturbance” under IDEA regulations, including the requirement of marked, long-term adverse effect on educational performance.
2. Whether the parents were entitled to tuition reimbursement for a unilateral private placement when the student was not IDEA-eligible.
3. What weight a reviewing court should give to the SRO’s decision compared to a hearing officer’s findings when the hearing officer relied primarily on a single document.

## Decision

- The Fourth Circuit affirmed the district court’s judgment upholding the SRO.
- The court held Edward did not meet the IDEA regulatory definition of SED and thus was not eligible for IDEA special education services.
- Because Edward was not IDEA-eligible, the parents were not entitled to tuition reimbursement for the unilateral private placement.
- The court credited the SRO’s determination over the hearing officer’s contrary finding, noting the hearing officer’s reliance on a juvenile-court psychiatrist letter and the broader evaluative record supporting the SRO.

## Legal Principles

- IDEA SED requires one or more specified characteristics shown “over a long period of time and to a marked degree” that “adversely affects” educational performance.
- The SED definition excludes students who are “socially maladjusted” unless they also satisfy the SED criteria.
- Juvenile delinquency, antisocial conduct, or a conduct disorder—without evidence meeting the regulatory SED characteristics and the required educational impact over time—does not establish IDEA eligibility.
- When administrative decisions conflict, reviewing courts may give significant weight to the final state-level administrative decision, particularly where it reflects a record-based application of the regulatory criteria.

## Conclusion

The court held that Edward’s misconduct and conduct disorder reflected social maladjustment and delinquency rather than an IDEA-defined serious emotional disturbance with a marked, long-term adverse effect on educational performance, so he was ineligible for IDEA services and his parents could not obtain reimbursement for their unilateral private school placement.


Springer v. Fairfax Cnty. Sch. Bd., 134 F.3d 659 (4th Cir. 1998)