T.R. v. School District of Philadelphia, Penn., No. 15-CV-04782 (E.D. PA. 2016)

Students of the School District of Philadelphia and their parents brought a class action lawsuit against the District, alleging violations of the Individuals With Disabilities Act (IDEA), Section 504 of the Rehabilitation Act, the Americans With Disabilities Act (ADA), the Equal Education Opportunities Act (EEOA), and Title VI of the Civil Rights Act of 1964. Plaintiffs alleged that the District’s provision of translation and interpretation services for LEP parents were inadequate, thereby depriving them of meaningful participation in the special education process. The court denied class action certification and granted summary judgment in favor of the defendant. The plaintiffs appealed. The Court of Appeals upheld the district court’s ruling, determining that the focus on inadequate translation and interpretation services wasn’t a claim that rose to the level of a systemic legal deficiency under IDEA. The claims did not meet IDEA’s exhaustion requirement, and the district court lacked jurisdiction.