U.S. Fifth Circuit - The FindLaw 5th Circuit Court of Appeals Opinion Summaries Blog

Court Cuts Back Special Ed Claim

Michelle Woody, a professor of biblical counseling, has faith that her battle with the Dallas Independent School District will end well. She has been fighting for her daughter's educational benefits for half a decade.

After losing more than $13,000 of her reimbursement claim from the school district, she appealed to the U.S. Fifth Circuit Court of Appeals for reconsideration. The appeals court sided with her in Dallas Independent School District v. Woody, and remanded the case to a trial judge.

Woody may have to pray harder, however, because the appeals court split the baby: she is entitled to reimbursement but not for everything she claims.

Disability Benefits

Kelsey Woody was a high school student with learning disabilities when her mother sought special education benefits in 2012. Living in Los Angeles at the time, the local school district said Kelsey was eligible for benefits.

Michelle was finishing an advanced degree at the University of Southern California at the time, and sent Kelsey to Dallas to live with her godparents. Meanwhile, the Los Angeles school district agreed to reimburse Michelle for private-school placement.

Michelle later moved to Dallas and sought benefits for her daughter from the school district there. In the meantime, Kelsey continued her private-school education.

The Dallas School District denied Michelle's request, but a hearing officer ruled the district owed her $25,426 as reimbursement. The trial judge reduced the award because it found that the mother's "conduct contributed in part to the imbroglio before the court."

A Miscalculation

On appeal, the Fifth Circuit said the trial judge erred in calculating benefits. Michelle wanted benefits to cover the entire 2013-2014 school year.

However, the appellate court said, the "district court erred by holding that the District was obligated to provide temporary services and by ordering reimbursement of the costs associated with such services."

On remand, the trial judge can award reimbursement because the district should have followed procedure. But the amount of reimbursement will be from April 24, 2014, to the end of that school year, the appeals court said.

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