Supreme Court of the United States

Florence County School District Four v. Carter, a Minor, by and Through Her Father and Next Friend, Carter

November 9, 1993510 U.S. 7

Summary

Justice O’Connor delivered the Court’s unanimous opinion affirming the Court of Appeals. The Court held that parents may obtain reimbursement under IDEA for an appropriate private placement following an inadequate public placement even though the private school does not satisfy all statutory requirements applicable to public education, including state approval. Those requirements do not govern unilateral parental placements. Reimbursement nevertheless depends on findings that the public placement violated IDEA and the private placement was appropriate, and courts must consider equitable factors and the reasonableness of the costs. There were no separate opinions.

Holding

  • Whether an otherwise appropriate parental private placement must satisfy every requirement of 20 U.S.C. § 1401(a)(18) to qualify for reimbursement.. Parents are not barred from reimbursement merely because their otherwise appropriate private placement fails to satisfy § 1401(a)(18), including its state-standards requirement.
  • What conditions and equitable limits govern reimbursement for unilateral private placements.. Reimbursement requires findings that the public placement violated IDEA and the private placement was proper under the Act. Courts must consider all relevant equitable factors, and full reimbursement is inappropriate when private educational costs are unreasonable.

Docket 91-1523

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