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Cedar Rapids Community School Dist. v. Garret F.

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Cedar Rapids Community School District v. Garret F.
Argued November 4, 1998
Decided March 3, 1999
Full case nameCedar Rapids Community School District v. Garret F., a minor, by his mother and next friend, Charlene F.
Citations526 U.S. 66 (more)
119 S. Ct. 992; 143 L. Ed. 2d 154
Case history
Prior106 F.3d 822 (8th Cir. 1997) (affirmed)
Holding
The exception for "medical services" from IDEA's related services provision only exempts services which must be provided by a physician.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityStevens, joined by Rehnquist, O'Connor, Scalia, Souter, Ginsburg, Breyer
DissentThomas, joined by Kennedy
Laws applied
Individuals with Disabilities Education Act

Cedar Rapids Community School District v. Garret F., 526 U.S. 66 (1999), was a United States Supreme Court case in which the Court ruled that the related services provision in the Individuals with Disabilities Education Act (IDEA) required public school districts to fund "continuous, one-on-one nursing care for disabled children" despite arguments from the school district concerning the costs of the services."[1]: 6  The judges relied heavily on Irving Independent School Dist. v. Tatro.[2][1] Under the Court's reading of the IDEA's relevant provisions, medical treatments such as suctioning, ventilator checks, catheterization, and others which can be administered by non-physician personnel come within the parameters of the special education law's related services.[3] Disability advocates considered the Court decision to be a "substantial victory for families of children with disabilities."[1]: 6  Amendments were made in the Education Flexibility Partnership Act of 1999 to increase IDEA funding as a result of the case.[1]: 6 

Background

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The Court reasoned in a seven to two decision, that Tatro established the bright-line rule, by which "the services of a physician (other than for diagnostic and evaluation purposes) are subject to the medical services exclusion, but services that can be provided in the school setting by a nurse or qualified layperson are not."[4]

Justices Clarence Thomas and Anthony M. Kennedy dissented, noting that the ruling "blindsides unwary states."[3]

References

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  1. ^ a b c d Ian O. Javier, ed. (2005), The Individuals with Disabilities Education Act (IDEA), Nova Science Publishers, Inc. 2013, ISBN 978-1594547102
  2. ^ Irving Independent School Dist. v. Tatro, 468 U.S. 883 (1984).
  3. ^ a b "Wrightslaw, article title The Supreme Court of the United States 526 U.S. 66 (1999) Cedar Rapids Community School District v. Garret F., a minor, by his mother and next friend, Charlene F." Retrieved October 6, 2014.
  4. ^ Cedar Rapids Community School Dist. v. Garret F., 526 U.S. 66, 72 (1999).
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