Eight-year-old Devin Taylor died of an asthma attack stemming from physical activity at school. His mother brought an action against Devin's teacher and School District, alleging violations of the Individuals with Disabilities Act (IDEA), the Rehabilitation Act and Americans with Disabilities Act, and Fourteenth Amendment substantive due process protections under § 1983. The District Court opinion responded to the Defendants' motion for summary judgment.
In response to the defendants' claim that Mrs. Taylor did not exhaust administrative remedies as required by the IDEA, the Court held that exhaustion would have been futile, and was therefore excused, because the monetary relief sought by a parent after the death of her child cannot be obtained through administrative proceedings. Although the IDEA claim survived summary judgment, it failed on the merits, because although Devin had a qualifying disability, there was no evidence that Devin needed specially designed instruction to receive an appropriate education. Although Mrs. Taylor disagreed with the School District's characterization of Devin's academic performance, she did not identify any material facts in dispute showing a genuine issue for trial.
The Court did believe that a genuine issue of material fact existed as to the adequacy of the action plan the school had put in place to respond to Devin's asthma, so it allowed Mrs. Taylor to proceed on her Rehabilitation Act / ADA claims. The Rehabilitation Act and the ADA prohibit recipients of federal funds from discriminating on the basis of disability. Both statutes have been interpreted to ensure that students with disabilities have a free appropriate public education. Because Mrs. Taylor's Rehabilitation Act and ADA claims were based on different facts from the ones supporting her IDEA claim, the failure of the IDEA claim did not require dismissal of the other claims.
The Court also permitted Mrs. Taylor to proceed on her Fourteenth Amendment substantive due process claim against the teacher, but not against the School District, finding that the municipality was not deliberately indifferent toward the rights of asthmatic children in its policies, regulations, or decisions.