N. T. v. Galesburg Community Unit School District No. 205

── N. T. v. Galesburg Community Unit School District No. 205 ── Court: Court of Appeals for the Seventh Circuit Date: May 06, 2026 Category: General In the United States Court of Appeals For the Seventh Circuit ____________________ No. 25-1013 N.T. and P.T., individually and as parents and next friends of C.T., Plaintiffs-Appellees, v. GALESBURG COMMUNITY UNIT SCHOOL DISTRICT NO. 205, Defendant-Appellant. ____________________ Appeal from the United States District Court for the Central District of Illinois. No. 4:24-cv-04124-JEH — Jonathan E. Hawley, Judge. ____________________ ARGUED SEPTEMBER 11, 2025 — DECIDED MAY 6, 2026 ____________________ Before BRENNAN, Chief Judge, and KIRSCH and JACKSON- AKIWUMI, Circuit Judges. BRENNAN, Chief Judge. C.T. is an elementary school student with disabilities. Due to his behavioral struggles, his parents agreed to place him in a special education class at his local elementary school in Galesburg, Illinois. Three weeks later, the school district proposed its first Individualized Education Plan. This would have placed him, against his parents’ 2 No. 25-1013 wishes, at a private therapeutic day school in a different school district in Peoria, Illinois. Rather than walk to his local school, C.T. would ride a bus more than 45 minutes each way. Believing this violated C.T.’s rights under the Individuals with Disabilities Education Act, his parents requested a due process hearing. After several days of testimony, an inde- pendent hearing officer concluded that the school district had complied with the Act. C.T.’s parents then sought judicial re- view. The district court conducted a bench trial and reversed the hearing officer’s decision. The court concluded that the school district’s attempt to place C.T. at the therapeutic day school would violate his right to an education in the least re- strictive environment. Because the district court’s decision in- volved no mistakes of law and was not clearly erroneous, we affirm. I. The IDEA Under the Individuals with Disabilities Education Act (IDEA or the Act), a state may receive federal funding to edu- cate children with disabilities as long as it adheres to certain conditions. 20 U.S.C. § 1412(a). Illinois has accepted such fed- eral funds, so it must comply. Id. The IDEA and its imple- menting regulations provide two substantive requirements. States shall provide eligible students with a free appropriate public education (FAPE), 20 U.S.C. § 1412(a)(1), in the least re- strictive environment (LRE), 20 U.S.C. § 1412(a)(5). Under the LRE provision, states can remove a child from the “regular education environment” and place him into “special classes,” “separate schooling,” or other restrictive op- tions, only when “the nature or severity of the disability … is such that education in regular classes with the use of No. 25-1013 3 supplementary aids and services cannot be achieved satisfac- torily.” Id. States shall also mainstream students with disabil- ities—that is, provide them an education with non-disabled peers—to the “maximum extent appropriate.” 20 U.S.C. § 1412(a)(5)(A). To these ends, states must make available “a continuum of alternative placements,” ranging from more to less mainstreamed. 34 CFR § 300.115. To provide a compliant education, schools evaluate whether a child qualifies for special education. 20 U.S.C. § 1414(a)–(c). If a child is eligible, the schools craft an individ- ualized education program, commonly referred to as an IEP. 20 U.S.C. § 1412(a)(4). This is a “written statement … devel- oped, reviewed, and revised” by a team of stakeholders. 20 U.S.C. § 1414(d)(1)(A)(i). An IEP team includes a child’s par- ents, teachers, and other qualified educators. 20 U.S.C. § 1414(d)(B). An IE