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Mills v. Board of Education of the District of Columbia, 348 F. Supp 866 (D. DC 1972)

Mills was a civil action brought in the federal US District Court for the District of Columbia on behalf of seven special-needs school-age children who sought their right to a free public education, which was being denied by the District of Columbia School Board. The case was granted class-action status (to represent the interests of similar DC school children) on December 21, 1971.

The Board of Education alleged the children were unable to be educated in public schools due to their "exceptional" needs, which included mental illness and mental retardation. The Board further claimed the cost of providing private educational services was too expensive; therefore, the children remained at home without access to an education.

Mills was resolved in a pretrail hearing, meaning the case was heard by a judge and there was no trial. The sitting judge was Joseph Cornelius Waddy, who was commissioned by President Lyndon Johnson in 1967.

Judge Waddy found in favor of the Plaintiffs (Mills et al.), and held that free public educational services, or a suitable private alternative paid for by the board of education, must be delivered based on the students' individual needs, regardless of cost to the school board.

"Constitutional rights must be afforded citizens despite the greater expense involved . . . the District of Columbia's interest in educating the excluded children clearly must outweigh its interest in preserving its financial resources. If sufficient funds are not available to finance all of the services and programs that are needed and desirable in the system then the available funds must be expended equitably in such a manner that no child is entirely excluded from a publicly supported education consistent with his needs and ability to benefit therefrom. The inadequacies of the District of Columbia Public School System whether occasioned by insufficient funding or administrative inefficiency, certainly cannot be permitted to bear more heavily on the "exceptional" or handicapped child than on the normal child."

"Plaintiffs' entitlement to relief in this case is clear. The applicable statutes and regulations and the Constitution of the United States require it."

For more information, see Related Questions, below.

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Mills v. Board of Education of the District of Columbia, 348 F. Supp 866 (D. DC 1972)

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Mills was a class action suit brought in US District Court for the District of Columbia on behalf of a group of school-aged children who were being denied their right to a free public education due to behavioral or developmental impairments that prevented them from attending mainstream classes.

The case was only heard in US District Court, so there were no "lower courts" involved, as US District Court is the court of original jurisdiction (trial court) for such matters.

The Court made its decision during a pretrial hearing; there was no trial for this case.

The District Court held there were no disputes of material fact and orally granted the plaintiffs' motion for a summary judgment on March 24, 1972 in favor of Mills (a summary judgment is a decision based on law when there is no need to hold a trial because the facts in a case are not in dispute).

The Court held, generally: "Plaintiffs' entitlement to relief in this case is clear. The applicable statutes and regulations and the Constitution of the United States require it."

Details

The plaintiffs filed suit in US District Court on September 24, 1971.

At the first pretrial conference, on December 17, 1971, Judge Waddy granted the plaintiffs (Mills, et al.) class action status, allowing Mills to represent all unnamed children in the District of Columbia whose interests were served by the outcome of the case.

On December 20, 1971, both plaintiffs and defendant agreed to, and the Court signed, an interim stipulation order requiring the school board to begin providing an appropriate education for four named plaintiffs by January 3, 1972; that the defendants provide a list of all known children with special needs, including home address and phone number as well as a summary of what was being done to meet those needs; and that the defendants identify remaining members of the class not currently known to them. Both parties were required to jointly consider selection and compensation for a "special master" who would be responsible for addressing questions arising about suitable placement for each child.

The Court held a second pretrial conference on January 14, 1972.

On January 21, 1972, Plaintiffs filed a motion for a summary judgment, and proposed a decree that the defendants file by March 1, 1972, a planned implementation strategy for fulfilling the requirements of law. Both parties requested a hearing.

On February 9, 1972, the Board of Education passed a Resolution which included the following:

Special Education

"All vacant authorized special education positions, whether in the regular, Impact Aid, or other Federal budgets, shall be filled as rapidly as possible within the capability of the Special Education Department. Regardless of the capability of the Department to fill vacant positions, all funds presently appropriated or allotted for special education, whether in the regular, Impact Aid, or other Federal budgets, shall be spent solely for special education."

On March 1, 1972, Defendants responded that they would provide the special needs children with an appropriate education, and submit an implementation plan by March 24. They also asked the judge to enter a simple declaratory judgment and complained that the motion for summary judgment was moot in light of the board's new resolution.

The judge set the date for a pretrial hearing for March 24, 1972. Defendants failed to comply with the court orders, and did not supply an implementation plan at the hearing, under the objection that the school board lacked sufficient funding to undertake the required plan of action.

Judge Waddy held the pretrial hearing as scheduled and determined there was no dispute of fact. The Board of Education cited cost and lack of funding as the reason it failed to provide an appropriate education to certain special education students. The court's decision was made on the basis of law, both constitutional and statutory, without trial.

The Court orally granted the Plaintiffs' motion for summary judgment, holding the plaintiffs were entitled to relief under the law. Judge Waddy cited specific statutes, board rules and precedents upholding his decision (see Related Questions).

"Constitutional rights must be afforded citizens despite the greater expense involved . . . the District of Columbia's interest in educating the excluded children clearly must outweigh its interest in preserving its financial resources. If sufficient funds are not available to finance all of the services and programs that are needed and desirable in the system then the available funds must be expended equitably in such a manner that no child is entirely excluded from a publicly supported education consistent with his needs and ability to benefit therefrom. The inadequacies of the District of Columbia Public School System whether occasioned by insufficient funding or administrative inefficiency, certainly cannot be permitted to bear more heavily on the "exceptional" or handicapped child than on the normal child."

"The Court has determined that the Board likewise has the responsibility for implementation of the judgment and decree of this Court in this case."

"Plaintiffs' entitlement to relief in this case is clear. The applicable statutes and regulations and the Constitution of the United States require it."

The Court issued its written opinion, with instructions, on August 1, 1972. The case was not appealed.

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