In Colin K. by John K. v. Schmidt, 715 F.2d 1 (1st Cir.1983), the father of learning disabled children challenged a state Individual Educational Program (IEP) placing the children in public school, and eventually secured the children's placement in a private facility. The district court affirmed the decision placing the children in private school, but it denied the father's claim for compensatory and punitive damages under the Education for All Handicapped Children Act of 1975 (EAHCA) and the Rehabilitation Act. The Court affirmed the district court's disposition of the damage claim. The Court first observed that compensatory and punitive damages were not available under the EAHCA, and the Court then held that in an action based on the substantive provisions of the EAHCA, plaintiffs could not use the arguably broader remedy of the Rehabilitation Act to expand the EAHCA's limited damage remedy: "In this context, ... the substantive rights imposed by the Rehabilitation Act derive wholly from the substantive requirements of the EAHCA. Although plaintiffs frame their challenge as one to defendants' discriminatory policy of not offering residential placement to learning disabled children, the focus of their complaint is that the policy reflects an error of educational judgment and does not satisfy the EAHCA requirement that plaintiffs be given residential placement necessary to provide them with a free appropriate public education. They do not suggest, nor is there any evidence suggesting, that defendants have any particular animus toward learning disabled children." 715 F.2d at 9-10.