SALT LAKE CITY, UTAH — The U.S. Court of Appeals for the Tenth Circuit has reversed a lower court’s dismissal of a lawsuit filed by two students with intellectual disabilities and the Disability Law Center against the Salt Lake City School District and its Board of Education. The plaintiffs allege the District’s special education “hub” system violates federal law by failing to make individualized educational placement decisions.
According to the appellate ruling, the District allegedly categorizes students based solely on IQ and assigns them to designated “hub” schools without assessing whether a more inclusive general education setting with supports would be appropriate. Plaintiffs contend this blanket approach disregards the requirements of the Individuals with Disabilities Education Act (IDEA), the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act (RA).
The Tenth Circuit found that the plaintiffs had plausibly alleged violations of all three statutes, rejecting the district court’s conclusion that the suit merely sought neighborhood school placement—a form of relief the court had previously found unavailable under the IDEA. Instead, the appellate panel emphasized the plaintiffs’ core claim: that the District does not perform the individualized analysis mandated by law.
The court also reversed the district court’s dismissal of the RA claim for failure to exhaust administrative remedies, holding that exhaustion would have been futile because similar ADA claims were already dismissed during administrative proceedings due to lack of jurisdiction.
However, the court affirmed that the individual plaintiffs had not properly challenged the specific rulings from their own administrative hearings and limited the remand to the systemic claims affecting similarly situated students.
The case has been remanded to the U.S. District Court for the District of Utah for further proceedings.
