Dellmuth v. Muth

Background

Alex is a bright child with a language learning disability. His father asked for a hearing under the federal Education of the Handicapped Act after disagreeing with the school district’s plan. While the appeal was pending the father placed Alex in a private special school and later sued the local school district and the Pennsylvania secretary of education. He sought money to repay private-school tuition, a court order fixing procedures, and attorney’s fees. The District Court and the Court of Appeals found procedural flaws and ordered the Commonwealth to help pay tuition, setting up the question whether the federal law lets people sue a State in federal court.

Reasoning

The Court addressed whether Congress clearly said states could be sued under the law. The majority said that to overcome the States’ immunity from suit in federal court Congress must make an unmistakably clear statement in the statute. The Court found that the special-education law’s general review provision, its preamble, and an attorneys’-fee amendment did not state that Congress intended to remove state immunity. Therefore the Court held the Commonwealth could not be forced to reimburse tuition in federal court and reversed the appeals court. Justice Scalia agreed with the result but noted Congress could still abrogate immunity if it uses clearer language.

Real world impact

The decision means parents cannot collect tuition reimbursement from the State in federal court under this law unless Congress writes clearer text. Families may still pursue claims against local school districts or in state court depending on state rules. The ruling preserves States’ general immunity from suits for money under the Act and could prompt Congress to amend the law if it wishes to allow suits.

Dissents or concurrances

Justice Brennan, joined by three colleagues, dissented and argued the statute and its history clearly showed Congress intended to allow suits against States; he would have upheld the lower courts’ reimbursement award.