## Facts

- Dylan Joseph White was a hearing-impaired public-school student in Ascension Parish, Louisiana, eligible for special education under the Individuals with Disabilities Education Act (IDEA).
- Dylan used a cochlear implant and a hearing aid and required in-class support from a cued speech transliterator to access spoken instruction in regular classrooms.
- The school system provided cued-speech transliterator services through a centralized model at three regular-education campuses (primary, middle, and high school), where hearing-impaired students were mainstreamed.
- Dylan attended one of the centralized campuses (Gonzales Primary) and received substantial academic benefit there.
- At an annual IEP meeting, Dylan’s parents requested placement at his neighborhood school for mainly social and convenience reasons, while still receiving needed services.
- The school district denied the request, citing its policy of providing cued-speech services only at centralized sites.
- IDEA administrative proceedings (local hearing officer and state review officer) upheld the district’s decision.
- The federal district court granted summary judgment to the parents and ordered Dylan assigned to his neighborhood school.
- The school board and officials appealed the injunction and related orders.

## Issues

1. Whether IDEA permits a school district to implement an otherwise appropriate IEP at a centralized campus rather than the child’s neighborhood school over parental objection.
2. Whether parents have a substantive right under IDEA to select the specific school site for service delivery when the child is receiving FAPE in the least restrictive environment.

## Decision

- The Fifth Circuit vacated the district court’s summary judgment and injunction requiring neighborhood-school placement.
- The court held that IDEA does not grant parents the right to demand a particular school site when the child is provided FAPE in an appropriate least restrictive environment.
- The court rendered judgment for the defendants on the site-selection issue and remanded for further proceedings consistent with its opinion.

## Legal Principles

- IDEA requires a free appropriate public education (FAPE) and education in the least restrictive environment (LRE) appropriate to the child, not placement in a particular neighborhood building.
- A school district may choose a centralized location for specialized services if the placement is reasonably calculated to confer educational benefit and the child is mainstreamed to the maximum extent appropriate.
- Parental participation in the IEP process is required, but parental preference does not control site selection when the district’s proposed placement satisfies IDEA’s substantive and procedural requirements.
- Courts generally defer to educational authorities’ reasonable programmatic and resource-allocation decisions once IDEA compliance (procedures and educational benefit) is shown, especially where administrative officers have upheld the placement.

## Conclusion

The Fifth Circuit held that a district may provide hearing-related services through centralized mainstreamed campuses and need not move a child to a neighborhood school when the existing placement delivers FAPE in the LRE and complies with IDEA’s procedures.


White ex rel. White v. Ascension Par. Sch. Bd., 343 F.3d 373 (5th Cir. 2003)