Case Citator › Ridgewood Board of Education v. N.E.

Ridgewood Board of Education v. N.E.

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Third Circuit
Citation
172 F.3d 238
Decided
Confirmed treatments
4
Flagged citations read
44 of 44
Citing cases (total)
44
Treatment dates
2007–2015
Abrogated
A reviewed court treats this case as abrogated by later authority. Ridgewood Board of Education v. N.E. has been abrogated in part. The Third Circuit later held that IDEA rights cannot be enforced through § 1983, and Congress imposed a two year filing period for IDEA hearing requests.
More on how this was screened

Two district courts also confined Ridgewood's Section 504 language when plaintiffs seek compensatory damages. These four treatments are listed below. All 44 flagged citations have been read.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

44 later cases cite Ridgewood Board of Education v. N.E.; 44 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Ridgewood Board of Education v. N.E.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The en banc court held that § 1983 cannot be used to remedy violations of IDEA rights, displacing Ridgewood's allowance of that route.

    A.W. v. Jersey City Public Schools · Third Circuit (en banc) · filed

    This, then, means that a § 1983 action is not available to remedy violations of IDEA-created rights, absent some “textual indication, express or implicit, that the [statutory] remedy is to complement, rather than supplant, § 1983.”
    Read the full opinion on CourtListener →

Superseded by statute

  • The 2004 IDEA amendments replaced Ridgewood's rule that compensatory education claims had no federal filing period with a two year deadline for hearing requests.

    P.P. ex rel. Michael P. v. West Chester Area School District · Third Circuit · filed

    In December of 2004, Congress passed amendments to the IDEA, which had an effective date of July 1, 2005. The previous version of the IDEA did not have a statute of limitations. The amendments, which we will refer to as “IDEA-2004,” included an explicit two-year statute of limitations: A parent or agency shall request an impartial due process hearing within 2 years of the date the parent or agency knew or should have known about the alleged action that forms the basis of the complaint, or, if the State has an explicit time limitation for requesting such a hearing under this subchapter, in such time as the State law allows. 20 U.S.C. § 1415(f)(3)(C). Pennsylvania does not have a separate explicit time limitation for these types of claims. Prior to IDEA-2004, we had held that there was no federal statute of limitations for compensatory education claims, in Ridgewood Board of Education v. N.E., 172 F.3d 238 (3d Cir.1999).
    Read the full opinion on CourtListener →

Limited

  • The court declined to apply Ridgewood's no intent rule for Section 504 liability to a claim for compensatory damages.

    Chambers v. School District of Philadelphia Board of Education · E.D. Pa. · filed

    The Chambers Plaintiffs’ reliance on the Third Circuit Court of Appeals’ decision in Ridgewood is unavailing. 172 F.3d at 253. Although in Ridgewood the court noted that “a plaintiff need not prove that [a] defendant[’s] discrimination was intentional” in order to state a claim under § 504, id. at 253, the court’s statement “does not contradict or even consider the rule that a plaintiff seeking compensatory damages must allege intentional discrimination.”
    Read the full opinion on CourtListener →

  • The court again declined to extend Ridgewood's no intent rule to Section 504 compensatory damages, which require intentional discrimination.

    Swanger v. Warrior Run School District · M.D. Pa. · filed

    despite Plaintiffs reliance on Ridgewood statement that- “a plaintiff need-not prove that- defendafits’ discrimination was intentional”, 172 F.3d at 253, we agree with the- substantial case law holding that the Third Circuit’s- reasoning does not preclude the requirement that a plaintiff seeking compensatory damages in a Section 504 claim must prove intentional discrimination.
    Read the full opinion on CourtListener →

Does this case still carry your argument?

Describe your facts. Ezel reads Ridgewood Board of Education v. N.E. and the cases that treated it, then tells you whether it still holds for your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace