Forest Grove School District v. T.A. Supreme Court Case: Implications for School Psychology Practice

Abstract

The 2009 Forest Grove School District v. T.A. United States Supreme Court case could have significant implications for school psychology practice. The Court ruled that the parents of a student with a disability were entitled to private school tuition reimbursement even though T.A. had not been identified with a disability or previously provided with special education services. The district multidisciplinary team had not identified T.A.’s disability in part because of a limited psychoeducational evaluation that did not assess him in “all areas of suspected disability” which is a requirement of the Individuals with Disabilities Education Act (IDEA; 20 U.S.C. § 1414(b)(3)(B)). Dissatisfied with the team’s decision, the parents sought an independent comprehensive evaluation of T.A.’s psychological processes which revealed the full nature of his disability and needs. Although T.A. had been unresponsive to interventions in his home school, this comprehensive psychoeducational evaluation led to more targeted interventions in his private school placement and likely contributed to T.A.’s subsequent academic and behavioral success. This Supreme Court case highlights the need for school-based teams to conduct comprehensive evaluations in all areas of suspected disability, including psychological processes such as attention, memory, and executive function. The relevant IDEA 2004 and governing 2006 federal regulations are presented, followed by recommendations for school psychologist assessment practices to ensure compliance with IDEA statutory and regulatory requirements.