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I will agree that the court's reasoning is a little tricky, but the conclusion is solid. When an injury involves educational harm to a student with a disability, it makes sense that the provisions of IDEA providing a right to a due process hearing should be utilized first before turning to court. I think that given the white hot public awareness of the abuse of seclusion and restraints, these cases will be on the rise.
Special ed hearing officers should be prepared. Of course, the issue before the hearing officer will not be damages to redress any physical injuries. That is still the province of the courts in places where such damages are available. The hearing officer can only rule on whether there is a violation of IDEA, the special education statute, and what remedies are appropriate to redress the educational harm. But given the exhaustion of administrative remedies ruling of the Payne court, and numerous similar decisions by other courts, hearing officers should be prepared for lots of seclusion and restraints abuse types of cases in the near future.
My crystal ball has been wrong before, but I think this prediction will come true.