Cedar Rapids Community School District, v. Garret F., a Minor by His Mother and Next Friend, Charlene F.’s Empirical Analysis
1999
Citation profile
47 federal appellate · 32 district · 12 state decisions
How this case has been cited
Cited by 145 later decisions (5 by the Supreme Court) — most recently January 2023 · most notably Schaffer Ex Rel. Schaffer v. Weast (2005), Arlington Central School District Board of Education v. Murphy (2006)
47 federal appellate · 32 district · 12 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedCedar Rapids Community School District v. Garret F. ex rel. Charlene F. (from Eighth Circuit Court of Appeals)
Relationships
Applies 20 U.S.C. § 1400 (Education for All Handicapped Children Act of 1975) · 20 U.S.C. § 1401 · 26 U.S.C. § 213 · 38 U.S.C. § 1701 (Faster Care for Veterans Act of 2016)
Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Board of Education of Hendrick Hudson Central School District Bd of Ed Westchester County v. Rowley · Patterson v. McLean Credit Union · Auer v. Robbins · Honig v. Doe
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 145 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) Determine whether the school district provided or made a FAPE available to the disabled child in a timely manner; if it did, the unilateral parental placement is not reimbursable. See 20 U.S.C. § 1412 (a)(10)(C)(ii); then (2) Determine whether the private placement is a state-accredited elementary or secondary school; if not, the placement is not reimbursable. Id. §§ 1412(a)(10)(C)(ii), 1401(27); then (3) Determine whether the private placement provides special education, i.e., “specially designed instruction ... to meet the unique needs 3 of a child with a disability”; if the placement provides no such instruction, it is not reimbursable. Id. § 1401(29)(A). (4) If the private placement provides additional services beyond specially designed instruction to meet the child’s unique needs, determine whether such additional services can be characterized as “related services” under the Act, ie., “transportation, and such developmental, corrective, and other supportive services ... as may be required to assist a child with a disability to benefit from special education,” excepting medical services which are not for diagnostic and evaluation purposes. Id. § 1401(26). If the additional services cannot be so characterized, they are not reimbursable.”
8 later decisions quote this exact passage · from the dissent“a free appropriate public education which emphasizes special education and related services designed to meet their unique needs.”
5 later decisions quote this exact passage · from the majority“encompasses those supportive services that 'may be required to assist a child with a disability to benefit from special education.'”
3 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.