## Facts

- T.G. was a student with a disability entitled to special education and related services under the Individuals with Disabilities Education Act (IDEA).
- Midland School District 7 conducted evaluations while developing T.G.’s individualized education program (IEP), including assessments in speech and language, occupational therapy, and assistive technology.
- The district’s evaluations were conducted by qualified professionals, were comprehensive, and examined T.G.’s performance and needs in the school setting.
- Although T.G.’s parents did not object to the district’s evaluations when they were conducted, they later obtained three separate private independent educational evaluations (IEEs) that addressed the same general areas.
- The parents sought reimbursement from the district for the cost of those IEEs.
- The matter proceeded through an IDEA administrative hearing process, where the hearing officer determined the district’s evaluations were appropriate and denied the parents’ request for reimbursement.
- The parents then sought review in federal district court.

## Issues

1. Under IDEA’s IEE regulations, were T.G.’s parents entitled to public reimbursement for three privately obtained IEEs when the district’s own evaluations were found appropriate?

## Decision

- The court upheld the administrative decision for the district.
- The court concluded the district’s evaluations satisfied IDEA standards and, as a result, the district was not required to reimburse the parents for the three IEEs.
- Judgment was entered for the district, and the parents were denied the requested reimbursement relief.

## Legal Principles

- IDEA permits a parent to obtain an independent educational evaluation at public expense only if the parent disagrees with an evaluation obtained by the public agency and the agency cannot show its evaluation was appropriate.
- When the school district proves its evaluation was appropriate under IDEA, reimbursement for a privately obtained IEE may be denied.
- IDEA evaluations must be sufficiently complete to identify the child’s special education and related-service needs, use appropriate assessment tools, and be administered by trained personnel.
- In an IDEA administrative review action, a federal court reviews the record while giving due weight to well-supported administrative findings, especially on educational methodology and the adequacy of evaluations.

## Conclusion

In *T.G. v. Midland School District 7*, the district court upheld the hearing officer’s determination that Midland’s speech/language, occupational therapy, and assistive-technology evaluations were appropriate under IDEA, and therefore the parents were not entitled to reimbursement for three private IEEs obtained after those district evaluations.


T.G. v. Midland School District 7, 848 F. Supp. 2d 902 (2012)