Clarification of Child Find Obligations and FAPE Requirements for Dyslexic Students under IDEA

1. Introduction

The Fifth Circuit’s decision in Moore-Watson v. Rankin County Public School District (5th Cir. May 2, 2025) clarifies key obligations under the Individuals with Disabilities Education Act (IDEA) relating to early identification of dyslexia (Child Find) and the standard for a Free Appropriate Public Education (FAPE). Tamatha Moore-Watson brought suit on behalf of her son M.W., alleging the district violated its duty to identify and properly serve his dyslexia and ADHD needs. After an administrative hearing and a district court ruling reversing part of the hearing officer’s decision, the School District and Moore-Watson both appealed. The Fifth Circuit affirmed the district court’s finding that the District failed its Child Find and FAPE obligations, upheld an award of attorneys’ fees, and denied private‐school tuition reimbursement.

2. Summary of the Judgment

The hearing officer initially ruled for the District on Child Find and FAPE, denying private tuition reimbursement.
The district court reversed on Child Find and FAPE, ordered independent-assessment reimbursement, directed a new evaluation for dyslexia/ADHD if M.W. re-enrolls, and awarded attorneys’ fees but denied tuition reimbursement for New Summit School.
The Fifth Circuit affirmed the district court in all respects: it held the school district violated IDEA by failing to identify dyslexia, did not provide a FAPE, that Moore-Watson was the prevailing party, and that New Summit School was not shown appropriate for tuition reimbursement.

3. Analysis

3.1 Precedents Cited

Endrew F. v. Douglas County: Established that an IEP must be “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances” and “appropriately ambitious.”
Michael F. v. Cypress-Fairbanks ISD: Articulated the four‐factor test for evaluating IEP adequacy: individualization, least restrictive environment, stakeholder collaboration, and demonstration of positive academic/nonacademic benefits.
Krawietz ex rel. Parker v. Galveston ISD: Clarified prevailing-party status under IDEA when an IEP is modified by court order.
Forest Grove School District v. T.A.: Held that private‐placement reimbursement requires showing the public placement violated IDEA and that the private placement was appropriate.

3.2 Legal Reasoning

The court’s reasoning follows a two‐step inquiry:

Child Find Obligations: IDEA requires districts to identify, locate, and evaluate children “suspected of having a disability” including dyslexia. The District missed multiple warning signs—kindergarten dyslexia screener failure, private tutor’s observations, independent dyslexia assessment—and did not evaluate or reevaluate M.W. timely. This failure violated 20 U.S.C. § 1412(a)(3) and triggered relief.
FAPE Standard: Applying Endrew F. and Michael F., the court found M.W.’s IEP deficient. The program was not tailored to his dyslexia/ADHD, the District denied reevaluation requests, key stakeholders (mother, dyslexia experts) were marginalized, and M.W. made only de minimis progress—ultimately failing second grade without IEP adjustment. The District’s Tier 2/3 interventions and limited speech services fell short of “appropriately ambitious” targets.

3.3 Impact of the Decision

Reinforces that districts must act on all credible information—screeners, tutor notes, parent input—to trigger Child Find evaluations.
Emphasizes the central importance of the fourth Michael F. factor—evidence of meaningful academic benefit—and the need to revise IEPs when a child is regressing or plateauing.
Clarifies that parents can secure court-ordered evaluations, IEP revisions, and attorneys’ fees even without obtaining tuition reimbursement for private placements.
Alerts districts to the risk of fee awards when they deny parental requests for reevaluation in the face of independent diagnoses.

4. Complex Concepts Simplified

Child Find: A proactive duty requiring schools to spot and evaluate students who might have disabilities—even absent formal referrals.
FAPE: A legal guarantee that each eligible child receives an individualized education plan designed for genuine learning progress, not minimal or token advancement.
Tiered Interventions: General‐education supports (Tier 1), small‐group help (Tier 2), and intensive one-on-one or small group (Tier 3) that precede special education referral.
Section 504 Plan: A civil‐rights plan providing accommodations for disabilities; it does not substitute for an IDEA IEP.
Prevailing Party: One who secures a material alteration in legal rights or responsibilities via court order—even if no monetary award is granted.

5. Conclusion

The Fifth Circuit’s Moore-Watson decision crystallizes two essential principles under IDEA: (1) School districts must promptly and fully evaluate a child for dyslexia and other disabilities once credible indicators arise; and (2) IEPs must be “appropriately ambitious,” with continuous stakeholder collaboration and measurable evidence of progress. Parents who secure court-ordered evaluations and IEP modifications qualify as prevailing parties and may recover attorneys’ fees even if private tuition reimbursement is denied. This case will guide lower courts and school districts in ensuring that children with dyslexia and ADHD receive timely identification, tailored services, and meaningful educational benefit under the IDEA.