In a groundbreaking decision that could reshape special education practices across the country, the Sixth Circuit Court of Appeals has affirmed that school districts cannot hide behind good grades and diplomas when students fail to master fundamental skills.
The case of William A. v. Clarksville-Montgomery County School System tells the story of a young man who graduated with honors but remained unable to read – and the legal battle his family waged to secure his educational rights.
William A. went through his entire middle school education without being able to read. Despite this, he sometimes earned high marks on assessments, giving the illusion of academic success. In reality, he was functionally illiterate.
Despite having an Individualized Education Plan (IEP) that included speech therapy and specialized instruction, the sole focus of his IEPs focused primarily on reading fluency while neglecting the critical building blocks of literacy – decoding and encoding skills that are particularly crucial for students with dyslexia.
As he progressed through school, his accommodations increasingly relied on technology and workarounds that masked, rather than addressed, his reading deficits.
The Turning Point
It wasn't until 11th grade that a perceptive teacher suggested William might have dyslexia. This late identification led his mother to seek private tutoring with Dr. Sarah McAfee, who implemented a structured, dyslexia-specific reading program. Under her guidance, William finally began to make meaningful progress.
When the school refused to incorporate this effective approach into his IEP, his parents took action, filing an administrative complaint under the Individuals with Disabilities Education Act (IDEA).
The Legal Journey
The case wound its way through three levels of legal review:
The Administrative Hearing: An Administrative Law Judge (ALJ) ruled that the school had violated IDEA by failing to provide William with an educational plan designed to help him learn to read. The remedy? An order for 888 hours of compensatory dyslexia tutoring. The ALJ also found violations under the Americans with Disabilities Act (ADA) and the Rehabilitation Act.
District Court Appeal: When the school appealed, the district court stood firm, upholding the ALJ's decision and reaffirming the 888-hour tutoring remedy, though it declined to specify that Dr. McAfee must provide the services.
Sixth Circuit Decision: The school's final appeal to the Sixth Circuit hinged on a critical argument: since William maintained good grades and graduated, hadn't he received an appropriate education? The court firmly rejected this reasoning.
The Court's Reasoning: Grades Aren't Everything
In its February 3, 2025 decision, the Sixth Circuit delivered a clear message: accommodations that allow a student to complete assignments without developing essential skills do not constitute an appropriate education under IDEA.
The court emphasized that the law requires education tailored to a student's unique needs – not just procedural compliance or passing grades. For William, whose capacity to learn reading was never in question, the failure to provide effective reading instruction violated the core purpose of IDEA.
Implications for Schools and Families
This ruling carries significant implications for students with dyslexia and other learning disabilities:
Beyond Grades: A student's GPA and diploma cannot be used as evidence of appropriate education if they mask fundamental skill deficits.
Meaningful Progress: IEPs must address actual learning needs, not just provide accommodations that bypass those needs.
Functional Literacy: The court recognized that for students capable of learning to read, literacy is an essential educational goal under IDEA.
Compensatory Services: The substantial remedy of specialized tutoring acknowledges the years of educational opportunity lost and the intensive intervention now required.
A Wake-Up Call for Educators
This case serves as a powerful reminder that the purpose of special education is not merely to move students through the system, but to equip them with the skills they need for meaningful independence. For students with dyslexia, this means providing evidence-based, structured literacy instruction that addresses their specific learning needs.
The William A. decision puts schools on notice: accommodations alone are not enough when they fail to address a student's capacity to learn essential skills. As this case demonstrates, parents have powerful legal recourse when schools prioritize procedural compliance over meaningful educational progress.
For families navigating similar challenges, this ruling offers both hope and a roadmap for advocacy. It reaffirms that the law stands behind the right of every student to receive an education that truly prepares them for life beyond the classroom walls.
Designed to Learn is dedicated to sharing information about educational rights, learning differences, and evidence-based practices. This article is intended for informational purposes and should not be taken as legal advice. For specific legal guidance, please consult with an attorney specializing in education law.