Sunday, October 27, 2013

Metropolitan School District v. Davila case brief

Metropolitan School District v. Davila case brief summary
969 F.2d 485 (1992)

Defendant United States Department of Education appealed a summary judgment from the United States District Court for the Southern District of Indiana entered in plaintiff school district's suit to void defendant's ruling regarding the Individuals with Disabilities Education Act (Act), 20 U.S.C.S. §§ 1411-20. Defendant contended that its rule was interpretative, and not subject to the notice and comment under the Administrative Procedure Act.

In response to a query from a state school district, defendant United States Department of Education issued a letter stating that under the Individuals with Disabilities Education Act (IDEA-B), 20 U.S.C.S. §§ 1411-20, school districts were required to provide educational services for eligible students who had been removed from the classroom for discipline reasons. Plaintiff school district challenged the rule on the ground that defendant had not followed the formal rulemaking dictates of the Administrative Procedure Act.

  • In reversing the judgment for plaintiff and entering judgment for defendant, the court held that defendant's rule was paradigmatically interpretive, not legislative, and thus was exempt from the formal notice and comment process under the statute. 
  • The court stated that defendant's characterization of the rule was entitled to some deference, and noted that defendant had acted as though it was interpreting the IDEA-B, not legislating. 
  • The court explained that neither the fact that the rule imposed substantive burdens on plaintiff nor that defendant's announcement was entirely novel necessarily qualified it as legislative.

The court reversed the judgment for plaintiff school district and ordered judgment entered for defendant United States Department of Education. The court held that defendant's letter ruling that plaintiff had a duty to provide educational services to disabled students it expelled from the classroom for disciplinary reasons was interpretive and not subject to notice and comment.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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