Patricia v. Board of Education of Oak Park River Forest High School District No the Illinois State Board of Education’s Empirical Analysis

Citation profile

1 federal appellate · 7 district · 1 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[A] parent's right to seek reimbursement for a unilateral placement of their child is available only upon a finding that, after cooperating with the school district, there are 'sufficiently serious procedural failures by the school district.'”

   3 later decisions quote this exact passage · from the majority
   e.g. Doe v. Cape Elizabeth Sch. Dep't · M.E. ex rel. C.E. v. Board of Education

2. ““the motion for summary judgment is simply the procedural vehicle for asking the judge to decide the case on the basis of the administrative record.” Heather S. by Kathy S. v. State of Wisc., 125 F.3d 1045, 1052 (7th Cir.1997) (citation omitted). Accordingly, despite being termed summary judgment, the district court’s decision is based on the preponderance of the evidence. See 20 U.S.C. § 1415 (e)(2) (1996); Hunger v. Leininger, 15 F.3d 664, 669 (7th Cir.1994). Indeed, a district court must independently determine whether the requirements of the Act have been satisfied. In developing this standard, Congress specifically rejected language which would have made state administrative findings conclusive if supported by substantial evidence. However, because courts do not have special expertise in the area of educational policy, they must give “due weight” to the results of the administrative decisions and should not substitute “their own notions of sound educational policy for those of the school authorities which they review.” Board of Educ. of Murphysboro v. Illinois Bd. of Educ., 41 F.3d 1162, 1166 (7th Cir.1994) (citations omitted) (emphasis added); see Morton Community Unit Sch. Dist. v. J.M., 152 F.3d 583, 587-88 (7th Cir.1998) (“[Cjourts (the district court and then this court, using the same standard) should give due deference to the hearing officers’ judgments.”); Heather S., 125 F.3d at 1052-53 .”

   2 later decisions quote this exact passage · from the majority
   e.g. 628 F. Supp. 2d 902 - Stanley v. MSD OF SW ALLEN COUNTY SCHOOLS · 101 F. Supp. 2d 707 - Doe v. Eagle-Union Community School Corp.

3. “[The County] had no opportunity to provide an appropriate education for [JH] in the public school as is preferred under IDEA because he transferred to private school ... without any discussion with [County] officials about possible accommodations to meet his current needs. Reimbursement for private education costs is appropriate only when public school placement under an individual education plan (IEP) violates IDEA because a child's needs are not met.... Since [the County] was denied an opportunity to formulate a plan to meet [JH's] needs, it cannot be shown that it had an inadequate plan under IDEA. Reimbursement for the costs of his private placement would therefore be inappropriate because school officials were excluded from the decision ... and because no showing of inadequate services under IDEA can be made.”

   2 later decisions quote this exact passage · from the majority
   e.g. L.K. ex rel. J.H. v. Board of Education · 113 F. Supp. 2d 856 - LK Ex Rel. JH v. BOARD OF ED. FOR TRANSYLVANIA COUNTY