Johnson Versus Independent School District Number 4

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Johnson versus Independent School District Number 4 was a milestone decision made by the US courts in the year 1990 (Boyle & Weishaar, 2001). The case was brought to court under the Education of All Handicapped Act of the year 1989. Through this act, all the states were required to enhance free and appropriate education for disabled children, recognize disabled kids as children with special needs, design special programs for disabled children, and ensure that appropriate environments are enhanced for disabled children to benefit from. Before the case, Natalie’s parents had requested Natalie’s school to offer their child with extended school year program during her summer period. The parent’s requests were turned down.


Natalie, who was 8 years at the time of this case, was a handicapped child. From the time she was 18 months old, Natalie had been getting learning assistance from the Children Development Centre (CDC). In a year, Natalie had been receiving regular education services for nine months. During summertime, she had been enrolled in a special recreational camp for eight weeks. Having not been satisfied with the services their child was getting from the recreation center, Natalie’s parents requested Natalie’s district school to provide her with extended educational programs. Upon their requests, the school administration held several meetings to discuss the request. After three months of discussions, the school rejected their request. Thereafter, Natalie’s parents invoked the due process of the Education of All Handicapped Act of the year 1989.


In this case, there were two legal questions on appeal. The court was required to outline the information measured as the base for prerogative under the Education of All Handicapped Act of the year 1989 besides the regular school programs (Julnes & Brown 2002). Equally, the court was required to state whether the Education of All Handicapped Act of the year 1989 required Oklahoma’s cooperative service providers to be an essential party.

Decision and previous decision in administrative hearings and the lower courts

During the hearing, Natalie’s father presented his evidence in testimonial forms. The testimonies were, drawn together from the child’s mother, pediatrician, neurologist, and psychologists. According to these experts, Natalie was supposed to continue receiving her extended educational services during her summertime. Similarly, during the hearing, the school representative presented their testimonials. The testimonials were drawn from the child’s class teachers and the speech therapist. According to the school representative, Natalie’s academic progress had not regressed when she was not enrolled in extended educational service. Similarly, the school representative presented evidence indicating that Natalie had not improved her performance even after being enrolled in extended educational service during the summer. Later on, the ruling officer identified that the child’s performance was unaffected by the extended educational services. In this regard, the hearing officer concluded that the child was not warranted to receive any extended educational service program. After the hearing officer, rejected their plea and ruled the case in favor of the school. Thereafter, the parents appealed the court’s decision. During the appeal decision process, the appeal officer affirmed the previous court ruling and asserted that parents and not the schools are required to meet the cost of supplementing the children’s extended education programs.

Having not been satisfied with the appeal officer’s ruling, Natalie’s parents sought further assistance by filing a case against CDC and the Oklahoma State Department of Education (McLynn, 1995). The case was filed in a district court in Oklahoma. When the US District Court ruled its decision, they asserted that Natalie’s rights to receive extension education services had been violated and ruled the case in favor of the parents. After losing the case in the District Courts, the schools appealed to the US Supreme Court. After analyzing the data presented before them, the Supreme Court reversed the District Court’s ruling. On the second legal question, the court concluded that CDC was not an essential party.


Regression-recoupment analysis was used as a test in this case. The courts used this scheme to evaluate the need for a structured summer program for handicapped children. During the test, the degree of regression, recoupment time, degree of impairment, and the parent’s ability to meet the cost of these extended programs were considered.

Scope of holding

This case was held in the state of Oklahoma during the year 1989. During the case, several representatives from the district schools, parents, and other educational stakeholders were present.


Based on the above analysis, it is apparent that the court arrived at its decision after analyzing the testimonials presented before them. The fact that the child’s performance regressed influenced the outcome of the court’s decision. This implies that the testimonials were used as a fundamental rationale in the case.

Unresolved issues

Even though the final court ruling was made in favor of the schools, it should be noted that there were several unresolved issues in the case. As such, the case ended before the courts could identify whether Natalie needed an extended education program. The Court asserted that the issue was to be remanded (Tanenhaus, 2008).


Boyle, J. R., &Weishaar, M. K. (2001).Special education law with cases. Boston: Allyn and Bacon.

Julnes, R. E., & Brown, S. E. (2002).Leading cases in special education law: edited court cases, 1992 . Seattle, Wash.: School Law Division, Institute for the Study of Educational Policy, College of Education, University of Washington.

McLynn, F. (1995).Famous trials: cases that made history. Pleasantville, N.Y.: Reader’s Digest Association.

Tanenhaus, D. S. (2008). Encyclopedia of the Supreme Court of the United States. Detroit: Macmillan Reference USA.

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ChalkyPapers. "Johnson Versus Independent School District Number 4." April 21, 2022.