Cedar Rapids Community School District v. Garret F.

Cedar Rapids Community School District v. Garret F., case in which the U.S. Supreme Court on March 3, 1999, ruled (7–2) that the 1990 Individuals with Disabilities Education Act (IDEA) requires school boards to provide continuous nursing services to disabled students who need them during the school day.

The case involved Garret F., a student in Cedar Rapids, Iowa, who was a quadriplegic and required a ventilator after his spinal column was severed in a motorcycle accident when he was four years old. (Because he was a minor at the time of the lawsuit, his full surname was omitted from court documents.) During the school day he needed a personal attendant to see to his health care needs, which included urinary catheterization, suctioning of his tracheostomy tube, and observation for respiratory distress. While he was in kindergarten through the fourth grade, his family provided the personal attendant. When he was in the fifth grade, his mother asked that the school board supply the needed nursing services. The board, however, refused.

After the parent requested a hearing under the IDEA, an administrative law judge decided that the school board was responsible for the services. A federal trial court in Iowa affirmed, concluding that such services did not fall within the “medical services” exclusion clause of the IDEA’s “related services” provision. The case then moved to the Eighth Circuit Court of Appeals, which noted that the Supreme Court’s earlier opinion in Irving Independent School District v. Tatro (1984) had established an unambiguous standard, whereby the services of a physician are exempted, but “services that can be provided in the school setting by a nurse or qualified layperson are not.” Since Garret’s services did not require a doctor, the court upheld the lower court’s decision.

On November 4, 1998, the case was heard before the Supreme Court. Given the court’s decision in Tatro, the school board did not argue that Garret’s care constituted medical services. Instead, it proposed that several other factors should be considered, and those included “whether the care is continuous or intermittent” and the expense of the service. Writing for the majority, Justice John Paul Stevens noted that the school district’s proposed test was not supported by the statute’s text or any other regulation. Focusing on the issue of expense, the court rejected accepting a cost-based standard, arguing that doing so would have required it to engage in judicial lawmaking without any congressional guidance. In the court’s view, Congress intended the IDEA to “open the door of public education” to all qualified students and to require school boards to “educate handicapped children with nonhandicapped children whenever possible.” Under the IDEA and the court’s own precedent, the justices ruled that a school board must fund such related services to help guarantee that students such as Garret were integrated into the public schools. Thus, the decision of the Eighth Circuit was upheld.