Schaffer v. Weast
This case involves a dispute between the Schaffers and the Board of Education of Montgomery County, Maryland. The Individuals with Disabilities Education Act (IDEA) requires public school systems to provide an Individual Education Program (IEP) for all disabled children in their jurisdictions. After the Schaffers learned of their child’s learning disability, they asked the Board for an IEP. Dissatisfied with the IEP proposed by the Board, the Schaffers enrolled their child in private school and sought reimbursement for the private school tuition in an administrative hearing.
Because the IDEA does not state who bears the burden of proof in such a hearing, the administrative judge placed the burden on the Schaffers because they brought the action. The Schaffers sought review in the district court, which held that the burden of proof should have been placed on the Board and returned the case to the administrative judge. The administrative judge ruled in favor of the Schaffers this time and ordered partial reimbursement of the private school tuition. The Board then challenged the administrative ruling, which the district court affirmed and ordered the Board to fully reimburse the Schaffers for the private school tuition. The Fourth Circuit Court of Appeals reversed the decision, holding that the burden of proof should have been placed on the Schaffers because the default rule places the burden of proof on the party bringing an action when a statute is silent on the matter.
Question Presented:
Under the Individuals with Disabilities Education Act, when parents of a disabled child and a local school district reach an impasse over the child’s
individualized education program, either side has a right to bring the dispute to an administrative hearing officer for resolution. At the hearing, which side has the burden of proof — the
parents or the school district?
