Cedar Rapids Community School District v. Garret F. by Charlene F. 526 U.S. 66, 119 S. Ct 992, 143 L.Ed. 2d 154 (1999)

FACTS: Garret F., a student in Cedar Rapids School District, is wheelchair bound and ventilator dependent due to a motorcycle accident at the age of 4. His mental capacity was unaffected. Garret is able to speak, control his wheelchair through the use of a puff and such straw, and operate a computer with a device that responds to head movements. Garret attends regular classes in a typical school program and his academic performance has been successful. Due to Garret being ventilator dependent, he requires a responsible individual to attend to certain physical needs while he is in school. During Garret’s first years in school, his family provided for his physical care during the school day. In 1993, Garret’s mother requested that the District take over financial responsibility for the health care services that Garret requires during the school day. The School District denied the request, stating that is was not legally obligated to provide continuous one-on-one services. Garret’s mother then requested a hearing with an Administrative Law Judge. The ALJ found that although Garret is the only ventilator dependent student in the District, most health care services that he required are already provided for some other students. The primary difference is that Garret is dependent on the ventilator for life support. The ALJ noted that school districts must provide school health services, to meet the maximum extent appropriate for all handicap children to attend school. The ALJ concluded that the District must bear responsibility for all services in dispute, including continuous nursing services. The District challenged the decision in Federal District Court. The Court affirmed the ruling of the ALJ. The District then challenged the issue in the Court of Appeals, which once again affirmed the ruling of the ALJ and District Court.

ISSUE: Does the performance of specific health care, such as ventilator monitoring, be a “related service” as outline by IDEA, qualify as an excluded “medical service”?

HOLDING: The Court affirmed the judgment of the Court of Appeals.

REASONING: The scope of “medical services” exclusion is not a matter of first impression in this Court. In Tatro, it was concluded that the Secretary of Education has reasonably determined that the term “medical services” refer only to services that must be performed by a physician, and not to school health services. It was thus settled in that the phrase “medical services” in IDEA did not embrace all forms of care that might be described as “medical”. In these instances, school districts must fund such “related services” in order to guarantee students like Garret are integrated in the publ