CHICAGO – An Illinois State Board of Education ruled last month that a school district’s obligation to provide educational services to a student with a disability goes far beyond a student completing required courses to graduate. The hearing officer found that the school district improperly graduated a young man with autism and failed to provide him with necessary education services to prepare him for employment, further education and independent living in violation of federal and state law.
Paris Washington, a twenty-year old young man with autism from Chicago Heights, was graduated from Bloom Township High School District 206 in May 2014 without receiving the legally-required individualized education services to prepare him for his transition to life post-high school. Each year, the school district passed him along further in high school without the required support and services. He and his mother, Cheryl Washington, only learned after he graduated that the school district had an obligation to provide these educational services. As a result, they filed a lawsuit with the Illinois State Board of Education (“ISBE”) seeking the required services to further his academic, career, and independent living pursuits.
The original hearing officer appointed by ISBE dismissed the case in January 2016 because she found that the school district’s obligation to the student ceased with graduation. Paris and his mother appealed to the U.S. District Court for the Northern District of Illinois where the court reversed the hearing officer’s decision and remanded the case for a hearing to determine if Paris was improperly graduated and denied a free appropriate public education.
A second ISBE hearing officer found that District 206 did not meet its obligations to Paris. Ruling that Paris was improperly graduated and denied an appropriate education, the hearing officer awarded him two additional years of instruction to develop employment, independent living and academic skills.
According to Olga Pribyl, Vice President of Equip for Equality’s Special Education Clinic, which represents Paris and his mother, the decision confirms that school districts must provide educational services to prepare a student to make the transition to adult life after high school and, for many students with disabilities, achieving the credits for graduation is not sufficient preparation. Importantly, parents who learn about educational violations that occurred while their children were in high school may still bring complaints regarding those violations even after graduation.
“This life-changing decision for Paris firmly instructs school districts that transition services are necessary for students with disabilities and cannot be overlooked,” said Pribyl. “We are pleased that the Hearing Officer has confirmed the central importance of individualized education services for students with disabilities.”
“No one from the school ever told me about transition services and I had no idea what they were when Paris was at Bloom High School,” said Cheryl Washington, Paris’s mother. “The school always told me that the goal was for Paris to graduate and go to college, but we never discussed what they would do to help him reach that goal. We are thrilled that Paris will finally get the transition services that he needs and deserves.”
“We hope this decision can be used to help parents across Illinois understand their school districts’ obligations to prepare students for further education, employment and independent living,” said Olga Pribyl. Equip for Equality attorneys Margie Wakelin and Melanie Grant are also representing Paris and his mother.
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A copy of the hearing officer’s decision can be provided upon request.
This publication is made possible by funding support from the U.S. Department of Health and Human Services, the Administration on Intellectual and Developmental Disabilities and the Center for Mental Health Services of the Substance Abuse and Mental Health Services Administration; the U.S. Department of Education, Rehabilitation Services Administration; and the Social Security Administration. The contents of this publication are solely the responsibility of Equip for Equality and do not necessarily represent the official views of any of these agencies.
