Florence Cty. Sch. Dist. Four v. Carter

In Florence Cty. Sch. Dist. Four v. Carter, 510 U.S. 7, 15, 114 S.Ct. 361, 366, 126 L.Ed.2d 284 (1993), the Court refused to bar reimbursement because the private placement the parents selected did not comply with the requirements for a Free Appropriate Public Education ("FAPE") under section 1401(18) of the IDEA in that it did not meet all of the education standards mandated for public schools. 510 U.S. at 13-14, 114 S.Ct. at 365-66. The Court reasoned that imposing such requirements on private placements would "eliminate the right of unilateral withdrawal recognized in Burlington v. Department of Educ., 471 U.S. 359, 105 S.Ct. 1996, 85 L.Ed.2d 385 (1985)." Ibid.