Schaffer, a Minor, by His Parents and Next Friends, Schaffer v. Weast

Summary

The Supreme Court held that at an IDEA 'impartial due process hearing' challenging an individualized education program (IEP), the burden of persuasion rests on the party seeking relief — here the disabled child's parents — because the Act is silent on allocation and the ordinary default rule assigns that burden to the claimant. The Court rejected arguments that constitutional due-process balancing, the landmark desegregation-era special-education rulings, IDEA's beneficent purposes, or school districts' informational advantage justified shifting the burden to districts, concluding that the Act's procedural safeguards, disclosure duties, and attorney's-fee provision neutralize any district advantage. Because Maryland had no contrary state law, the Court affirmed the Fourth Circuit while expressly reserving whether States may override the default rule. Justice Stevens concurred; Justices Ginsburg and Breyer dissented — Ginsburg would place the burden on school districts, and Breyer would leave the question to the States and remand.