A.L., a nine-year-old student with dyslexia and other learning disabilities, sued the Special School District of St. Louis County and Ferguson-Florissant School District in the U.S. District Court for the Eastern District of Missouri, raising claims under the Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act, the Americans with Disabilities Act (ADA), and the Missouri Human Rights Act (MHRA). Defendants moved to dismiss all claims under Rule 12(b)(6).
Factual Overview
A.L., diagnosed with dyslexia and other learning disabilities, struggled with reading from kindergarten through fourth grade. Despite poor performance on reading assessments and placement in reading intervention programs, the school districts did not evaluate him for learning disabilities or notify his parents about his reading difficulties. After A.L.’s mother requested accommodations and evaluation in late 2022, the districts initially denied her requests but eventually evaluated A.L. in mid-2023, finding him eligible for special education services. The Administrative Hearing Commission (AHC) found that the districts violated their child-find obligations under IDEA and ordered 1,386 minutes of compensatory education services. The plaintiffs then filed this lawsuit seeking additional relief.
Legal Analysis
IDEA Claims: The court found that Count I, alleging failure to provide a free appropriate public education, was time-barred because it was filed outside Missouri’s 45-day limit for appealing AHC decisions. However, the court allowed Count II for attorneys’ fees to proceed, finding that plaintiffs qualified as prevailing parties due to the compensatory education award.
Disability Discrimination Claims:The court permitted the Section 504 and ADA claims to proceed, finding that plaintiffs adequately alleged bad faith or gross misjudgment through the districts’ prolonged failure to identify A.L.’s disabilities and provide appropriate services.
MHRA Claim: The court dismissed the MHRA claim because plaintiffs failed to exhaust administrative remedies by not filing a charge with the Missouri Commission on Human Rights before bringing suit.
The court granted the motion to dismiss as to Counts I (IDEA violation) and V (MHRA claim) but denied the motion as to Counts II (attorneys’ fees), III (Section 504), and IV (ADA).
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