N.T. and P.T., individually and as parents and next friends of C.T. v. Galesburg Community Unit School District No. 205

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 C OMMUNITY U NIT S CHOOL 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.
____________________
A RGUED S EPTEMBER 11, 2025 — DECIDED M AY 6, 2026
____________________
Before BRENNAN , Chief Judge, and K IRSCH and JACKSON -
A KIWUMI , 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’

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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

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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 IEP must be tailored to meet the individual
needs of the disabled child by stating the student’s present
levels of performance, setting measurable annual goals, and
explaining how progress toward meeting those goals will be
measured. 20 U.S.C. § 1414(d)(1)(A)(i). It must also list the
special education and related services, along with any addi-
tional support and services, that each disabled student will
receive. Id.
Parents who believe an IEP violates their child’s statutory
rights are entitled to review. Relief may be sought in state
administrative proceedings. 20 U.S.C. § 1415(f)(1)(A). Illinois
enacted qualifications and guidance for the independent
hearing officers who conduct such proceedings. 105 ILCS
5/14-8.02c. Any party “aggrieved by the findings and deci-
sion” of a hearing officer may sue in state or federal court. 20
U.S.C. § 1415(i)(2)(A).

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4 No. 25-1013
In such cases, the court “(i) shall receive the records of the
administrative proceedings; (ii) shall hear additional evidence
at the request of a party; and (iii) basing its decision on the
preponderance of the evidence, shall grant such relief as the
court determines is appropriate.” 20 U.S.C. § 1415(i)(2)(C).
The party challenging the outcome of the administrative hear-
ing bears the burden of proof. Alex R. ex rel. Beth R. v. For-
restville Valley Cmty. Unit Sch. Dist. No. 221, 375 F.3d 603, 611
(7th Cir. 2004) (citation omitted). Though the district court in-
dependently evaluates the witnesses and evidence and can
expand the record with an evidentiary hearing, the hearing
officer’s findings and decision are still entitled to “due
weight.” See Alex R., 375 F.3d at 612 (7th Cir. 2004) (citing Bd.
of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S.
176, 206 (1982)); see also Beth B. v. Van Clay, 282 F.3d 493, 497
(7th Cir. 2002). And though Congress authorized courts to
base their decisions on the preponderance of the evidence,
this is not “an invitation” for courts “to substitute their own
notions of sound educational policy for those of the school au-
thorities which they review.” Rowley, 458 U.S. at 206.
II. Background
When this dispute began, C.T. was a six-year-old student
in the first grade.1 According to his parents and educators,
C.T. enjoys science and shows promise in math. He displays
good motor and problem-solving skills, and he possesses a
strong vocabulary and good sense of humor. Yet due to his
attention deficit hyperactivity disorder, mild oppositional de-
fiant disorder, generalized anxiety, and sensory disturbance,
C.T. often struggles with aggression, leaves the classroom,
1 C.T. is currently nine years old and enrolled in third grade.

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No. 25-1013 5
refuses work, and interacts negatively with peers and super-
vising adults. At times, his behavior has escalated to cursing
and physical violence, including kicking and throwing class-
room items, causing minor injuries to staff.
A. Behavior Interventions
Thus far, C.T.’s education has included several interrup-
tions and interventions. He briefly entered kindergarten at Si-
las Willard Elementary before transferring to King Elemen-
tary. Due to behavioral issues in the regular classroom at
King, the principal and other administrators took turns
providing dedicated one-on-one support to C.T. throughout
the day.
That fall, after C.T. started first grade, the Galesburg Com-
munity School District conducted a Functional Behavior As-
sessment and instituted a Behavior Intervention Plan for C.T.
His behavioral struggles continued, however. Seeking resolu-
tion, the school district and C.T.’s parents entered a mediation
agreement. That placed him back at Silas Willard in a self-con-
tained classroom for students with emotional and behavioral
disorders (“EBD”).
The EBD classroom provides embedded social-skills train-
ing and therapeutic activities. At the time, it consisted of seven
students, a special education teacher, and two paraprofes-
sional aides. Several students at Silas Willard also receive in-
dividualized support from dedicated one-on-one aides.
B. Individualized Education Plan
After further evaluation, C.T. was deemed eligible for spe-
cial education. In December 2023, three weeks after placing
him in the EBD classroom, the school district proposed C.T.’s
first IEP. The plan set out several functional and behavioral

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6 No. 25-1013
goals. But the IEP team determined that C.T. would not bene-
fit from a one-on-one aide, explaining that such dedicated
support would not allow C.T. to learn to ask for help. And
rather than C.T. continuing in the EBD classroom, the IEP rec-
ommended placing him at High Road School of Peoria.
High Road is a private therapeutic day school that offers a
high teacher-to-student ratio and a small classroom environ-
ment. It enrolls exclusively disabled students with no main-
streaming opportunities. The school provides embedded so-
cial-emotional learning, a dedicated behavior interventionist,
and a weekly on-site board-certified behavior analyst. High
Road is also in a different school district and would require
C.T. to take a 45-minute bus ride each way without dedicated
adult supervision.
C. Administrative Hearing
When the school district denied requests to revise the IEP,
C.T.’s parents asked for a due process hearing before an inde-
pendent hearing officer. 20 U.S.C. § 1415. In their view, and
relevant here, High Road was not the least restrictive environ-
ment for C.T.’s education.
The hearing officer conducted a three-day hearing in
March and April 2024. She heard the school district’s wit-
nesses opine that a one-on-one aide was not needed. None of
C.T.’s classmates received such assistance, and C.T received
continual individualized attention. Further, the hearing of-
ficer heard testimony that C.T. requires a therapeutic day
school to meet his behavioral and educational needs. On this
point, she found the school district’s testimony “overwhelm-
ing, credible, persuasive, and uncontroverted by Parents at
the hearing.”

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No. 25-1013 7
After reviewing the full administrative record, the hearing
officer found the following:
• C.T. had made no progress;
• the EBD program could not meet his behavioral and
academic needs;
• additional supports and services, including a one-on-
one aide, were unnecessary; and
• C.T. ultimately required a therapeutic day school.
The hearing officer thus concluded that C.T. could not re-
ceive a “satisfactory education” in Silas Willard’s EBD class-
room, and that High Road’s therapeutic day school was the
least restrictive environment.
D. Judicial Review
C.T.’s parents sought judicial review in federal district
court. 20 U.S.C. § 1415(i)(2)(A). The complaint automatically
triggered a statutory “stay put” injunction, which has kept
C.T. at Silas Willard throughout this dispute. 20 U.S.C.
§ 1415(j).
In October 2024, the district court held a bench trial to sup-
plement the administrative record with additional evidence.
Seven witnesses testified. New testimony, not heard by the
hearing officer, focused on developments related to C.T.’s be-
havioral and educational setting since the administrative
hearing. C.T.’s parents testified concerning his friendships
and his increasingly positive relationship with his teacher.
C.T.’s teacher shared that his behavior had shown some im-
provement. And although she struggled to gain C.T.’s trust
and observed some worsening in his behavior after summer
break, she testified his “physical aggression is not

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8 No. 25-1013
fundamentally different from his peers.” Further, she partly
blamed his IEP for any deterioration because it was not tai-
lored to help him succeed in Silas Willard’s EBD classroom
during the “stay put” period.
Testimony also provided context and corrected infor-
mation on the benefits of a one-on-one aide. The district court
heard from expert witnesses who had not testified at the ad-
ministrative hearing. For one, C.T.’s new occupational thera-
pist, after observing him in the EBD classroom, reported that
staff were often distracted by other students’ needs and spent
more time documenting his behaviors than they did assisting
him. Because of this, C.T.’s occupational therapist opined that
C.T. was not receiving the individualized help he needed. For
another, C.T.’s private counselor testified that a one-on-one
aide could effectively implement recommended interven-
tions, helping C.T. to stay on task and regulate his emotions
before they escalate to a behavioral incident. In contradiction
to evidence before the hearing officer, the district court
learned that other students at Silas Willard had been provided
one-on-one aides.
In December 2024, the district court reversed the hearing
officer’s decision. After a review of the full record—consisting
of the administrative hearing record, the hearing officer’s
opinion, and evidence adduced at the bench trial—the court
found it “more likely than not … that C.T. can receive a satis-
factory education in [Silas Willard’s] EBD classroom with ad-
ditional interventions.” In support of its ruling, the court
found that since the administrative hearing, C.T. had made
“significant progress,” developed positive relationships, and
would benefit from a one-on-one aide in the EBD classroom.
So, to the court, the school district’s placement at High Road’s

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No. 25-1013 9
therapeutic day school violated the IDEA’s LRE provision.
The court thus ordered the school district to “create an appro-
priate” IEP to educate C.T. in Silas Willard’s EBD classroom.
The school district appeals.
III. Discussion
Our analysis proceeds in three parts. First, we discuss the
standard of review that courts of appeals apply when evalu-
ating claims under the IDEA. Second, based on that discus-
sion, the issues of law raised in this case are evaluated. Third,
finding no mistakes of law, we move to the district court’s ul-
timate decision that the school district violated the Act’s least
restrictive environment provision. Mindful of the deference
owed to the professional educators who crafted C.T.’s indi-
vidualized education plan, we conclude that the district court
committed no clear error.
A. Standard of Review
In the briefs and at oral argument, there was some confu-
sion about the applicable standard of review. This is under-
standable. The classic articulation, repeated often but rarely
explained, is not a picture of clarity: “Although we review the
school [district]’s ultimate decision de novo because it is a
mixed question of law and fact, we will reverse only if the dis-
trict court’s findings were clearly erroneous, absent a mistake
of law.” Beth B., 282 F.3d at 496 (citing Bd. of Educ. of LaGrange
Sch. Dist. No. 105 v. Ill. State Bd. of Educ., 184 F.3d 912, 915 (7th
Cir. 1999)). An apparent tension exists in this formulation be-
tween reviewing de novo and reversing only for clear error.
Adding to the confusion, more recent cases simplify the
standard of review without quoting the older language. See,
e.g., Alex R., 375 F.3d at 612 (“On appeal, our review of

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10 No. 25-1013
questions of law is plenary and our review of the district
court’s findings of fact is for clear error.”) (citing Beth B., 282
F.3d at 496); Bd. of Educ. of Twp. High Sch. Dist. No. 211 v. Ross,
486 F.3d 267, 270 (7th Cir. 2007) (“[W]e should review the …
district court’s findings of fact deferentially. We will reverse
only if those findings are clearly erroneous … . We review
questions of law, as usual, de novo.”). For all that, this updated
language leaves unclear whether the ultimate decision—law
applied to fact—is a question of law or a finding of fact.
This court’s caselaw harmonizes the apparent tension in
two ways. First, only pure questions of law are reviewed de
novo. An example is whether a district court applied the
wrong standard. See, e.g., Beth B., 282 F.3d at 497 (reviewing
“as a matter of law” whether the wrong substantive standard
for evaluating the LRE was applied); Alex R., 375 F.3d at 612–
13 (reviewing as an issue of law “whether the district court
applied the correct legal standard in determining whether
Alex received an adequate IEP” (citation modified)). Second,
the district court’s underlying factual findings and ultimate
decision concerning statutory compliance—law applied to
fact—are reviewed for clear error. See id. at 612, 615–16, 618
(treating the district court’s decision on whether an IEP com-
plied with the FAPE and LRE provisions as a finding of fact
reviewed for clear error); Ross, 486 F.3d at 270, 276–78 (same).
This aligns with how mixed questions of law and fact are
generally reviewed. See, e.g., United States v. Vivirito, 65 F.4th
341, 343 (7th Cir. 2023) (“A district judge’s handling of a
mixed question usually is reviewed deferentially, even when
that decision resolves the ultimate issue in a case.”). Yet
“[m]ixed questions are not all alike.” See U.S. Bank N.A. v. Vill.
at Lakeridge, LLC, 583 U.S. 387, 395–96 (2018). Which standard

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No. 25-1013 11
to apply in reviewing a mixed question depends on “whether
answering it entails primarily legal or factual work.” Id. at
396. When answering a mixed question requires courts to “ex-
pound on the law” and develop “auxiliary legal principles of
use in other cases,” review should be de novo. Id. But for other
mixed questions that “immerse courts in case-specific factual
issues—compelling them to marshal and weigh evidence
[and] make credibility judgments,” the district court’s deci-
sion is reviewed with “deference.” Id.
The mixed question here is case-specific and primarily en-
tails factual work. True, when courts do not receive additional
evidence in IDEA cases, the district court and the appellate
court review the administrative record, findings, and decision
from the same evidentiary vantage point. But when addi-
tional evidence is considered by the district court, as here, that
court exercises discretion in admitting that evidence, assesses
the credibility and persuasiveness of witnesses in person,
weighs the evidence on the full record, and bases its decision
on the preponderance of the evidence. See Monticello Sch. Dist.
No. 25 v. George L., 102 F.3d 895, 901 (7th Cir. 1996). In this
way, the district court resolves factual disputes and is closer
to the evidence than the appellate court. For such fact-inten-
sive determinations, de novo review would be inappropriate.
See Vill. at Lakeridge, 583 U.S. at 395–96. So, especially when
the district court hears additional evidence, we show defer-
ence to its decision and reverse only for clear error.
We proceed next to pure issues of law, which as just dis-
cussed are reviewed de novo.

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12 No. 25-1013
B. Issues of Law
The school district argues that the district court made
three mistakes of law. One concerns deference owed to the
administrative decision. A second is about how evidence is
weighed. As for the third, the school district characterizes the
district court’s ultimate decision as an issue of law: “[T]he
District Court erred as a matter of law when applying the
IDEA’s LRE mandate to the facts of this case.” But because we
review that decision for clear error, we discuss it in a separate
section. See infra III.C.
1. Due weight
The school district submits that the district court failed to
give “due weight” to the hearing officer’s findings and deci-
sion. On legal issues, hearing officers receive no deference.
Alex R., 375 F.3d at 611. On issues of fact, the district court
independently evaluates the witnesses and evidence, and it
must accord “due weight” to the hearing officer’s findings
and decision. See id. at 612 (citing Rowley, 458 U.S. at 206); see
also Beth B., 282 F.3d at 497. This “due weight” requirement
arrives as a gloss on the statutory text, which the Supreme
Court inferred from Congress’s choice to have courts “receive
the records of [state] administrative proceedings.” Alex R., 375
F.3d at 612 (citing Rowley, 458 U.S. at 206).
The meaning of due weight “varies from case to case.” Id.
When a district court receives no new evidence and relies
solely on the administrative record, “due weight” means
“clear error” or “substantial evidence.” Sch. Dist. of Wis. Dells
v. Z.S., 295 F.3d 671, 674–75 (7th Cir. 2002) (treating “clear er-
ror” and “substantial evidence” as functionally the same,
given the judicial mind’s inability to make such fine

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No. 25-1013 13
distinctions, and collecting cases); Alex R., 375 F.3d at 612
(“This level of review is akin to the standards of clear error or
substantial evidence.”).
But when the district court receives additional evidence,
due weight is evaluated on a “sliding scale.” Z.S., 295 F.3d at
675. The “more that the district court relies on new evidence
… the less it should defer to the administrative decision:
‘[j]udicial review is more searching the greater the amount
(weighted by significance) of the evidence that the court has
but the agency did not have.’” Alex R., 375 F.3d at 612 (quoting
Z.S., 295 F.3d at 675). At the “opposite extreme” from cases
with no new evidence, “the administrative decision is rela-
tively less important and the district court effectively acts as
the factfinder.” Id.
In evaluating legal issues on a sliding scale, case analogies
and distinctions become particularly instructive. Take Alex R.
There, as here, both parties “adduced new evidence.” 375 F.3d
at 613. The parents submitted a newspaper article and “exten-
sive affidavits” from various witnesses. Id. The school district
presented several IEPs and “supporting documents,” along
with an affidavit from a building administrator. Id. at 613–14.
This court thus concluded “(1) that this case is close to the end
of the spectrum at which the hearing officer was entitled to
much less deference and (2) that the district court did not err
by giving the hearing officer’s findings and decision insuffi-
cient weight.” Id. at 614.
In reaching that result, this court reasoned that the “new
evidence” was “a significant part of the total record before the
district court” in sheer “amount.” It was also “very im-
portant” to the court’s decision. Id. Moreover, this court em-
phasized that the district court had “specifically noted that it

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14 No. 25-1013
reviewed both the administrative record and the evidence put
forth for the first time before [it].” Id.
This case is like Alex R. The district court here received a
significant amount of material evidence that the hearing of-
ficer had not considered. It conducted a bench trial with seven
witnesses and more exhibits. The new testimony included
post-hearing developments that, to the district court, “im-
pacted both C.T.’s behavior and educational setting.” New ex-
perts also opined on C.T.’s experience in the EBD classroom
and his need for the individualized support of a one-on-one
aide. As in Alex. R., the new evidence in this case was “a sig-
nificant part of the total record before the district court.” Id.
Further, the new evidence was “very important” to the
district court’s findings and decision. Id. Several pages of its
opinion were dedicated to this testimony. In evaluating its
significance, the court found “[C.T.’s] parents, along with the
private professionals involved in his care, credibly and per-
suasively advocate[d] for a one-on-one aide.” Moreover, in
the court’s view, the school district’s witnesses did not “con-
test these opinions per se,” but merely repeated their testi-
mony from the administrative hearing that C.T. had enough
attention and would not benefit from a one-on-one aide. The
court found this “[in]sufficiently address[ed] the need for this
level of individualized support.”
Moreover, as in Alex R., the district court said it reviewed
both the administrative record and the new evidence before
reaching a decision based on the preponderance of the evi-
dence. See id. The court articulated the correct standard of re-
view, expressly acknowledging the “due weight” owed to the
hearing officer’s findings and decision. And in the end, the
court’s decision that C.T. could receive a satisfactory

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No. 25-1013 15
education in the EBD classroom with additional reasonable
measures, including a one-on-one aide, relied heavily on post-
hearing developments and new expert testimony not re-
viewed by the hearing officer. So, the reasoning from Alex R.
controls. The hearing officer’s findings and decision in this
case are entitled to less deference, and the district court did
not err by giving them the weight it did.
The school district disagrees, likening this case to Z.S.
There, this court concluded that additional evidence received
by the district court was “[im]material” and “seems not to
have played a significant role in the district court’s decision.”
Z.S., 295 F.3d at 675–76. That case was thus “near the bottom
of this sliding scale” and “essentially a no-new-evidence
case,” so it was subject to clear error or substantial evidence
review. Id. Yet the district court’s opinion in Z.S. “contain[ed]
language” suggesting it did the “forbidden and, despite not
having taken material new evidence, made an ‘independent’
determination that the school district had not violated the
IDEA.” Id. at 676. In Z.S. the district court thus applied “the
wrong standard of review” as a matter of law. Id.
Z.S. is inapposite. Here, the additional evidence was ma-
terial, significant in amount, and important to the district
court’s reasoning and conclusion. For similar reasons, Ross is
also distinguishable. There, the district court heard “some ad-
ditional testimony,” Ross, 486 F.3d at 273, but it was an insig-
nificant part of the record relative to the vast administrative
proceedings. The hearing officer in Ross had “heard testimony
for 42 days,” making it the “longest special education due
process hearing in Illinois history.” Id. Moreover, the new ev-
idence was not important to the district court’s decision,
which “rel[ied] heavily on the hearing officer’s decision.” Id.

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16 No. 25-1013
at 277. Like Z.S., Ross was functionally a no-new-evidence
case, meaning the standard of review was for clear error or
substantial evidence. Id. Not so here. For these reasons, the
district court did not err as a matter of law by failing to accord
significant weight to the results of the administrative pro-
ceedings.
2. Trial de novo
The school district next asserts that, by placing too much
weight on new evidence from the bench trial, the district court
conducted an impermissible trial de novo. For support, the
school district cites to language in Monticello. There, after ac-
knowledging the district court’s discretion to allow additional
evidence under § 1415(i)(2)(C), this court cautioned that
judges “must be careful not to allow such evidence to change
the character of the hearing from one of review to a trial de
novo.” Monticello, 102 F.3d at 901 (quotation omitted). But this
language from Monticello and subsequent cases concerns
whether the district court abused its discretion by admitting
too much additional evidence, not by weighing it improperly
once admitted. Id. at 901–02; see, e.g., Patricia P. v. Bd. of Educ.
of Oak Park, 203 F.3d 462, 469–70 (7th Cir. 2000). In this way,
the school district overreads Monticello. Yet there is no need to
do so; parties can challenge how evidence is weighed by as-
serting a court’s failure to accord “due weight” or by showing
clear error. So, the school district’s trial de novo argument
must be rejected.2
2 As for challenging discretionary decisions about admitting evidence,
at the bench trial the school district objected to only one expert witness’s
testimony. In its briefing, the school district recounts this objection with-
out developing an argument for abuse of discretion. That challenge is thus

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No. 25-1013 17
* * *
Because the district court committed no mistakes of law,
we proceed to its ultimate determination—that the school dis-
trict’s placement of C.T. at High Road’s therapeutic day
school violated his right to be educated in the least restrictive
environment. That decision can be reversed only if clearly er-
roneous, though we remain mindful of the deference owed to
professional educators.
C. Least Restrictive Environment
Recall that in enacting the LRE provision of the Act, Con-
gress expressed a strong preference for mainstreaming. Stu-
dents with disabilities cannot be removed from the “regular
education environment” and placed into “special classes,”
“separate schooling,” or other options, unless “the nature or
severity of the disability … is such that education in the regu-
lar classes with the use of supplementary aids and services
cannot be achieved satisfactorily.” 20 U.S.C. § 1412(a)(5)(A).
And when a student is placed elsewhere on the “continuum
of alternative placements,” 34 CFR § 300.115, states must se-
lect the placement that mainstreams the child to the “maxi-
mum extent appropriate.” 20 U.S.C. § 1412(a)(5)(A).
The implementing regulations add relevant guidance, too.
When “selecting the LRE,” school districts must consider
“any potential harmful effect on the child or on the quality of
services” needed. 34 CFR § 300.116(d). The placement must
be “as close as possible” to the child’s “home.” 34 CFR
§ 300.116(b)(3). It must be “in the school that he would attend
waived. See Bradley v. Village of University Park, 59 F.4th 887, 897 (7th Cir.
2023).

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18 No. 25-1013
if nondisabled,” unless the child’s IEP requires otherwise. 34
CFR § 300.116(c). And states must provide a disabled child re-
verse mainstreaming opportunities—that is, nonacademic
and extracurricular activities alongside non-disabled peers—
to the “maximum extent appropriate to the needs of that
child.” 34 CFR § 300.117; see also § 300.107.
But the preference for mainstreaming students with disa-
bilities is not absolute. The Supreme Court has yet to interpret
the LRE provision, but it has noted that the Act’s use of “ap-
propriate” in 20 U.S.C. § 1412(a)(5)(A) “seems to reflect Con-
gress’ recognition that some settings simply are not suitable
environments for the participation of some handicapped chil-
dren.” Rowley, 458 U.S. at 197 n.21.
1. Framework for evaluating the LRE
Without much guidance, nearly every circuit has adopted
a multi-factor test.3 This court has consistently avoided doing
3 The Fourth, Sixth, and Eighth Circuits employ a feasibility test, ask-
ing whether the services that make the segregated placement superior
could be feasibly provided in the non-segregated setting. If so, the benefits
of both settings, the child’s disruptive effect, and the costs of mainstream-
ing are weighed. Roncker v. Walter, 700 F.2d 1058, 1063 (6th Cir. 1983); A.W.
v. Nw. R-1 Sch. Dist., 813 F.2d 158 (8th Cir. 1987); DeVries v. Fairfax Cty. Sch.
Bd., 882 F.2d 876 (4th Cir. 1989). The Fifth Circuit, viewing the feasibility
test as too intrusive on educational-policy choices, adopted a two-step test:
courts ask (1) whether the education in the regular classroom, with the use
of supplementary aids and services, can be achieved satisfactorily for the
child; and, if not, (2) whether the school’s new placement mainstreams the
child to the maximum extent appropriate. Daniel R.R. v. State Bd. of Educ.,
874 F.2d 1036, 1048 (5th Cir. 1989). Each step involves a factor-based, “in-
dividualized, fact-specific inquiry” into each child and the school’s re-
sponse. Id.; see also Greer v. Rome City Sch. Dist., 950 F.2d 688 (11th Cir.
1991); Oberti v. Bd. of Educ. of Borough of Clementon Sch. Dist., 995 F.2d 1204
(3d Cir. 1993); L.B. ex rel. K.B. v. Nebo Sch. Dist., 379 F.3d 966 (10th Cir.

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No. 25-1013 19
so. See Lachman v. Ill. State Bd. of Educ., 852 F.2d 290, 294–96
(7th Cir. 1988); Bd. of Educ. of Murphysboro Cmty. Unit Sch. Dist.
No. 186 v. Ill. State Bd. of Educ., 41 F.3d 1162, 1168 (7th Cir.
1994); Monticello, 102 F.3d at 906; LaGrange, 184 F.3d at 916–
17. As explained in Beth B., “the Act itself provides enough of
a framework for our discussion.” 282 F.3d at 499.
That “framework” has two steps: At step one, the question
is whether the child received a satisfactory education in the
regular classroom, or could receive one with additional rea-
sonable measures. If the answer is yes, then removal from the
regular classroom violates the Act. If the answer is no, the in-
quiry at step two is whether the new placement mainstreams
the child to the maximum extent appropriate. Id.; Ross, 486
F.3d at 277.
In Beth B., this court said step one “demands a hard look
and a careful analysis of the education” the student was re-
ceiving in the regular education classroom. 282 F.3d at 498.
Without listing specific factors, the court’s “hard look” fo-
cused largely on Beth’s virtually nonexistent “academic pro-
gress” and minimal “developmental progress.” Id. at 499. A
“modicum of developmental achievement,” the court held,
“does not constitute a satisfactory education.” Id. At step two,
this court concluded that “so long as [the special education
classroom] includes reverse mainstreaming opportunities” it
is at an “acceptable point along the ‘continuum of services’
between total integration and complete segregation” and
2004); P. ex rel. Mr. and Mrs. P. v. Newington Bd. of Educ., 546 F.3d 111 (2d
Cir. 2008). The Ninth Circuit chose a pure balancing approach that draws
on factors from both tests. Sacramento City Unified Sch. Dist. v. Rachel H., 14
F.3d 1398, 1403–04 (9th Cir. 1994).

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20 No. 25-1013
mainstreams Beth to the maximum extent appropriate. Id. (ci-
tations omitted).
In Ross, this court affirmed the district court’s determina-
tion that the child was not receiving a satisfactory education
in the regular classroom. 486 F.3d at 270, 276–78. There, the
district court had found that the child was “not making mean-
ingful progress,” possessed “minimal” ability to interact with
peers, spent little time in class, and displayed aggressive and
violent behaviors that were “disruptive” to others in the reg-
ular classroom. Id. at 277–78. On appeal, this court empha-
sized the deference owed to the district court’s “findings of
fact” and “conclusion,” making it “easy” to affirm. Id. at 270,
277–78. At step two, the court concluded that the new place-
ment mainstreamed the child appropriately under the Act. Id.
at 277–78 (“[T]he recommended placement school[] present[s]
‘reverse mainstreaming opportunities,’ which allow for inte-
gration into the regular education environment and periodic
interaction with nondisabled students.”)
The concern about “meaningful progress” has aged well.
More recently, the Supreme Court held that an IEP makes
available an “appropriate” education—for purposes of the
Act’s free appropriate public education requirement
(FAPE)—as long as it is “reasonably calculated to enable a
child to make progress appropriate in light of the child’s cir-
cumstances.” Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch.
Dist. RE-1, 580 U.S. 386, 399 (2017). The inquiry of Endrew F.
differs from the inquiry into the LRE, but it is instructive. If
the education a child receives in the regular education envi-
ronment, or could receive with additional reasonable
measures, does not result in “progress appropriate in light of
the child’s circumstances,” it is not satisfactory, so removal

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No. 25-1013 21
would not violate the Act.4 Beyond the concern for progress,
our circuit has resisted supplying a definition of “satisfactory
education” or a list of factors for evaluating it. And although
comparisons to Beth B. and Ross are helpful, each child is dif-
ferent and requires an individualized, fact-specific inquiry
when evaluating the LRE.
2. Satisfactory education
At every stage, the parties, hearing officer, and district
court assumed the LRE analysis in this case begins at step one.
That is not exactly correct. Step one asks whether the child can
be removed from the regular classroom and placed into some
form of segregated special education. 20 U.S.C. § 1412(a)(5)(A).
But by mutual agreement between his parents and the school
district, C.T. has already been removed from general educa-
tion and placed in the segregated EBD classroom. His parents
4 With FAPE claims, courts review only whether the “prospective
judgment by school officials” expressed in an IEP was “reasonably calcu-
lated” to enable progress for the individual child. There is no “guarantee”
of “any particular [educational] outcome.” Endrew F., 580 U.S. at 398. In
that context, only the prospective judgment is reviewed for compliance
with the Act. And it is not limited to the regular classroom but applies to
any placement.
By contrast, the hard look at whether a child receives a “satisfactory
education” for LRE purposes focuses on the regular classroom. It is also
retrospective and, in some cases, prospective. It looks back at the educa-
tion the child has been receiving in the regular classroom under his IEP
(retrospective), but if not satisfactory, it also assesses whether it could be
made satisfactory with additional reasonable measures (prospective).
And unlike the FAPE inquiry, if the LRE analysis at step one shows an
education is not and could not be achieved satisfactorily, that does not
violate the Act. Just the opposite. It means the removal was not a violation,
and the analysis proceeds to step two of the framework in Beth B. and Ross.

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22 No. 25-1013
hope to keep him there. But where to place C.T. on the “con-
tinuum” of alternative placements is a step two question. So,
if High Road mainstreams C.T. to the maximum extent appro-
priate, the IDEA does not prevent this new placement.
As far as placements go, High Road is as restrictive as a
placement can be. Per C.T.’s IEP, that school enrolls exclu-
sively students with disabilities and has no mainstreaming or
reverse mainstreaming opportunities. It is not the school C.T.
would attend if not disabled, and it is much farther from
C.T.’s home. The only potential harm considered in the IEP
was the lack of mainstreaming, but the district court heard
testimony of various ways the placement could negatively
impact C.T.’s development. By contrast, the EBD classroom
mainstreams C.T. to a greater extent and is less restrictive. So,
the Act requires that C.T. remain in the EBD classroom as long
as it would be “appropriate.”
In this case, in which one placement on the continuum of
alternative placements is in a different school district and is
significantly more restrictive than another, steps one and two
dovetail. See, e.g., S.H. v. State-Operated Sch. Dist. of City of
Newark, 336 F.3d 260, 272 (3d Cir. 2003) (“[T]he LRE would
ideally be the same school the child would have attended if
[he] were not disabled … [but] such placement is only appro-
priate to the extent that it ‘satisfactorily educates’ the disabled
child.”). Inquiring into the appropriateness of the EBD class-
room requires a fact-intensive, careful examination of the ed-
ucation C.T. has received or could receive there with addi-
tional reasonable measures. So, in this case, we treat this in-
quiry like the “hard look” at step one.
In the school district’s view, an EBD classroom cannot pro-
vide C.T. with a “satisfactory education.” Yet after conducting

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No. 25-1013 23
a bench trial and reviewing the full record, the district court
determined otherwise, finding it “more likely than not … that
C.T. can receive a satisfactory education in [Silas Willard’s]
EBD classroom with additional interventions.”
For support, the district court found that, in the time be-
tween the administrative hearing and the bench trial, C.T.
made “significant progress” and formed “positive relation-
ships” in the EBD classroom. The court observed that by
March 2024, C.T. had reached a behavioral goal in his IEP that
he was not expected to reach until December 2024. Moreover,
C.T.’s math and reading standardized test scores improved
dramatically. Tweaks in C.T.’s medication regimen, the court
noted, had resulted in positive outcomes, and his private
counselor testified to improving emotional regulation. As to
positive relationships, C.T.’s mother testified to his friend-
ships in the EBD classroom and shared that C.T. perceives his
teacher as supportive and as the only one who has not given
up on him yet. C.T.’s new occupational therapist, who made
a short observational visit to the EBD classroom, reported that
C.T. joked around playfully with his classmates.
The district court also found that C.T. would benefit from
a one-on-one aide. C.T.’s new occupational therapist further
testified that staff were often distracted by other students’
needs and spent more time documenting C.T.’s behaviors
than assisting him. A private counselor testified that a one-
on-one aide could effectively implement recommended inter-
ventions, which could help C.T. stay on task and regulate his
emotions. The court also learned, contrary to what was told
to the hearing officer, that other students at Silas Willard re-
ceived one-on-one aides. And in evaluating this testimony,
the court found “[C.T.’s] parents, along with the private

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24 No. 25-1013
professionals involved in his care, credibly and persuasively
advocate[d] for a one-on-one aide.”
Finally, the district court was sensitive to the timing of
C.T.’s change in placement. The school district recommended
a new placement only three weeks after C.T. joined the EBD
classroom, before he had a chance to receive an education un-
der an IEP tailored to enable progress in light of his individual
circumstances. The school district warns that considering this
factor will have unintended consequences and negative prec-
edential effects. Schools, they argue, will not be able to appro-
priately place students in more restrictive learning environ-
ments unless, and until, they exhaust every possible measure.
But each case, like each student, is different. In evaluating
whether a student could receive a satisfactory education, a
district court can at least consider the absence of meaningful
evaluation of a student’s performance under an adequate IEP.
In the school district’s view, the district court ignored evi-
dence and relevant considerations. It points to the “full scope”
of C.T.’s behavioral issues and their disruptive effect, reduc-
tions in C.T.’s academic workload to avoid frustration, his
worsening behavior after summer break, and testimony that
C.T.’s teacher struggled to build trust with him. Yet, C.T.’s
teacher testified that his “physical aggression is not funda-
mentally different from his peers.” Reductions in workload
are part and parcel of the EBD classroom accommodation,
and it seemed to work because C.T. made improvements. As
for deterioration, C.T.’s teacher partly blamed his IEP, which
was not designed to help him succeed in the EBD classroom.
And the court took that seriously. In short, after our careful
review of the record, we find no clear error and thus do not
reverse.

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No. 25-1013 25
3. Deference to Professional Educators
The school district also argues the district court failed to
defer to professional educators who crafted C.T.’s IEP. On this
point, the Supreme Court acknowledged—when interpreting
the Act’s FAPE provision—that judicial review is not “an in-
vitation to the courts to substitute their own notions of sound
educational policy for those of the school authorities which
they review.” Rowley, 458 U.S. at 206. This court interpreted
that language from Rowley to mean that IEPs are reviewed for
reasonableness. Z.S., 295 F.3d at 676 (citing Rowley, 458 U.S. at
206–07) (“The critical issue … was whether the school admin-
istrators were unreasonable.”); Ross, 486 F.3d at 278 (“[W]e
cannot undertake an independent assessment … we can only
decide whether the hearing officer … came to a rational con-
clusion.”).
The Supreme Court has since clarified the meaning of this
language, again in the FAPE context. Deference to decisions
made in an IEP, the Court explained, derives from the “appli-
cation of expertise and the exercise of judgment by school au-
thorities.” Endrew F., 580 U.S. at 404. But given the nature of
the IEP process, “respective opinions” will be “fully air[ed].”
Id. And by the time a “dispute reaches court,” school author-
ities will have had a “complete opportunity to bring their ex-
pertise and judgment to bear on areas of disagreement.” Id.
So, reviewing courts may “fairly expect” those authorities to
offer a “cogent and responsive explanation for their deci-
sions.” Id. Though district courts may not substitute their own
views, they need not accept rational explanations that lack co-
gency and responsiveness to other views.
Given this clarification, the district court did not substitute
its own views or fail to defer to professional educators on

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26 No. 25-1013
educational issues. The point of an IEP is to make goals easily
measurable. A court is as equipped as professional educators
to evaluate fact questions under an IEP, such as progress to-
wards goals, relationship formation, and whether a child gets
along with others.
Even when deference was owed, the district court gave it.
Assessing the severity of C.T.’s disruptive effect in the EBD
classroom, for example, involves some expertise. But on this
point, the court heard conflicting testimony from the profes-
sional educators. C.T.’s teacher testified that his behavior was
no worse than the other students in the EBD classroom. By
crediting testimony from one professional educator over an-
other, the district court did not fail to accord deference.
Evaluating additional reasonable measures, like a one-on-
one aide, also implicates expertise. Yet, the district court
found explanations for why C.T. did not need a one-on-one
aide wanting for cogency and responsiveness. After C.T.’s
private experts opined on the benefits of a one-on-one aide,
the district court found that the school’s witnesses repeated
their views from the administrative hearing without “con-
test[ing] [opposing] opinions per se.” These explanations also
differed from the initial reason given by the IEP team. Finally,
the school district did not explain why other children at Silas
Willard received one-on-one aides or how their individual
needs differed from C.T.’s. This made the decision to deny
C.T. such dedicated support look arbitrary.
IV. Conclusion
The district court held that the school district’s placement
of C.T. at High Road’s therapeutic day school violated the
IDEA’s least restrictive environment requirement. In reaching

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No. 25-1013 27
this conclusion, the district court made no mistakes of law.
Nor did it clearly err in its factual findings or in concluding
that C.T. can receive a satisfactory education in Silas Willard’s
EBD classroom with additional reasonable measures, like a
one-on-one aide.
A FFIRMED

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