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A class of disabled students sued the Pennsylvania Department of Education, claiming that the state's special education funding formula violated the Individuals with Disabilities Act ("IDEA"), the Americans with Disabilities Act ("ADA"), and the Rehabilitation Act ("RA").
Finding the state's funding formula valid, the students' claims failed after a bench trial, and the Third Circuit affirmed.
The Pennsylvania Funding Formula
Under the IDEA, if a state provides funds for special education, they become eligible for federal funds if they provide a free appropriate public education ("FAPE") to eligible students. To determine the amount of funding to allocate, Pennsylvania has developed a formula that assumes 16% of students in each district is disabled, and dividing that amount among all districts.
The plaintiff class consisted of students in districts with 17% or more special needs students enrolled. Because the formula was based on a 16% rate, the amount the students received for their education was $3,327, compared to $4,108 for students in other districts where the percentage was 16% or lower.
At trial, the students alleged that they were denied a FAPE under the IDEA, and discriminated against under the ADA and RA. The district court found that the students failed to prove a systematic denial of FAPE, or a causal link between the lower funds and the denial of a FAPE. On the ADA and RA claims, the court found that because they did not show a violation of the IDEA, the also did not prove violations of the ADA and RA.
The students appealed only on the denial of the ADA and RA claims.
Deprived of Meaningful Access?
Though success on an IDEA claim is not a prerequisite for success on ADA and/or RA claims, the Third Circuit noted that the disabled students had to prove they were deprived of a benefit or opportunity provided to non-disabled students, because of their disability. The court found that the disparate impact here was not prima facie evidence of discrimination, and stated that plaintiffs failed to provide evidence that they were "deprived of meaningful access to a benefit to which he or she was entitled."
This case undoubtedly is a disappointment for parent of students with disabilities, because if they happen to live in a district with a higher than 16% rate of students with disabilities, they may have to accept a little less funding per student. However, if they can provide evidence proving that the disabled students are deprived of a service that non-class members are getting, they have a chance of success.