How are you handling dysgraphia?

The folks in the Bainbridge Island school district thought they had done as much evaluation as they needed to do.  The court did not see it that way.  There had been numerous expressions of concern from both parents and teachers over the student’s ability to write.  However, the district never conducted an evaluation to determine if the student had dysgraphia. When pressed in court, the district argued that dysgraphia was merely secondary to dyslexia, which the school did evaluate. The court disagreed:

But as Dr. Nelson made clear, P.S.’s dysgraphia is not merely secondary to dyslexia, it is a separate condition for which P.S. received an independent diagnosis.

The court held that the district committed a procedural violation by failing to evaluate the student’s possible dysgraphia.  Moreover, this procedural violation denied FAPE by depriving the student of needed services and the parents of the opportunity to participate meaningfully.

Federal law does not specifically include dysgraphia in the list of conditions that might constitute a specific learning disability.  It includes dyslexia, but not dysgraphia.  See 34 CFR 300.8(c)(10).  However, Texas Education Code 38.003 speaks of “dyslexia and related disorders” and includes “developmental dysgraphia” as one of the “related disorders.”  The Dyslexia Handbook gives the subject considerable attention, addressing dysgraphia from page 59 to page 72!

So perhaps this could happen here as well.  This case is D.S. v. Bainbridge Island School District, decided by the federal court for the Western District of Washington in 2021.  We found it on Special Ed Connection at 78 IDELR 242.


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