Reaffirming the Rights of Disabled Students

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Cedar Rapids Community School District v. Garret F. was a Supreme Court case that reaffirmed the rights of disabled students to receive certain health services at the expense of the school district. The Supreme Court ruled in favor of a student who required daily care that the District argued it was not responsible to provide because of cost. Seven justices disagreed with Cedar Rapids and upheld a previous ruling on the Individuals with Disabilities Education Act.

The concept of related services comes from the Individuals with Disabilities Education Act to ensure that disabled students are able to benefit from the special education to which they are entitled. Related services are determined on an individualized basis and districts are only required to cover medical services that are must be provided by a doctor (Katsiyannis & Yell, 2000). When a district must provide medical services, those instances require the service to be necessary for the child to benefit from the education, the service has to occur during the school day and an individual who is not a doctor can be trained to provide the care needed (Katsiyannis & Yell, 2000). Those are stipulations that would become important in the Supreme Court’s ruling in Irving Independent School District v. Tatro, which ultimately established a bright-line test that stipulated if a doctor was needed to provide the service, the district was not responsible, but if someone else can be trained to perform the procedure, the district must provide the service.

In the case of Cedar Rapids Community School District v. Garret F., the Supreme Court administered its bright-line test once again. The high court ruled in favor of the student, noting that, first, Garret could not be in school without the services and, second, the services he needed could all be performed by a trained person other than a licensed doctor. The District, however, felt that Garret’s required services were a financial burden to the district and went well beyond what was required in the Tatro case (Katsiyannis & Yell, 2000).

The District proposed its own test that would determine if a school district was ultimately required to provide such services on an individual basis. The District argued that the test should consider if the care required is continuous if the district already has employees who can provide the service, how expensive the service is, and what would happen if the service is not given adequately. The Supreme Court rejected this test, noting that its requirements do not already legally exist. The Court also found that continuous versus intermittent care made no difference in terms of the already-existing bright-line test and that long-term care did not change the fact that the services could be provided by someone other than a physician (Cedar Rapids, 1999). Ultimately, the Court determined that the test established in Tatro continued to provide a logical and just interpretation of the laws.

Garret Frey’s parents were right to challenge the district in court, and I believe I would have done the same thing had I been Garret’s parents. There had been a clear legal precedent set forth by the Supreme Court in the Tatro case, and from the onset, it appeared that Garret’s case met all the requirements to pass the bright-line test. It was also apparent that the district was attempting to have the test altered to better suit its financial needs, which would have in turn placed the burden on the family. For that reason, I would have pursued the case in court, especially with a case as strong as Garret’s.

Ultimately, the importance of the Garret F. case is that it reaffirmed the right to education for disabled students regardless of certain medical conditions that may have been denied to them by the school district without the rulings in Tatro and Garret F. While Tatro established the bright-line test, Garret F. reaffirmed it and even went a step further in striking down the financial argument proposed by the district. It is a ruling that is considered a landmark victory for disabled students in the United States.


Cedar Rapids Community School District v. Garret F. 526 U.S. 66. (1999). Retrieved from

Katsiyannis, A. & Yell, M.L. (2000). The Supreme Court and School Health Services: Cedar Rapids v. Garret F. Exceptional Children, 66 (3), 317-326.