In Compton Unified School District v. Starvenia Addison, a parent sued the school district seeking compensatory services because she alleged the district should have known her daughter, Addison, was eligible under IDEA, long before it found her eligible. The facts, as alleged, are disturbing. While in high school, Addison failed all of her classes, played with crayons at her desk, played with dolls and urinated on herself. Still, the district continued to promote her from grade to grade. As the Court explained, “Addison’s mother was reluctant to have her ‘looked at,’ and School District officials decided not to ‘push.’” Finally, Addison’s mother requested an evaluation. The district granted her request, and the team found her eligible.
This case comes on the heels of the well publicized Forest Grove v. T.A. where the U.S. Supreme Court ruled a student does not have to have received special education services from a district to be eligible for reimbursement for private education. In combination, the cases stand for an expansion of the principle of child find.It is unclear whether the District will appeal this case to the U.S. Supreme Court. Regardless, it foreshadows what is certain to be an issue in the coming reauthorization of IDEA: when does a district refuse service?