Office for Civil Rights Findings on Grundy County Schools in Tennessee
OCR Complaint 04-23-1064 focuses on exclusion from activities and a path toward inclusion.
Background
March 18, 2026, U.S. Department of Education’s Office for Civil Rights (OCR) entered into a resolution agreement with Grundy County Schools (GCS) in Tennessee. Six days later, March 24, 2026, OCR issued its letter of findings to GCS. The underlying complaint, filed in 2022, alleged that the district discriminated against a student with a disability by excluding him from school activities and changing his Individualized Education Program (IEP) in ways that restricted his participation.
The Complaint and Allegations
A parent filed the complaint on behalf of her son, a student with disabilities attending a school in GCS. According to the letter, the parent alleged the following:
Exclusion from activities: After an IEP meeting on 26 October 2022, school staff revised the student’s IEP to bar him from any extracurricular or school‑wide events. The complainant alleged that this caused the student to miss his brother’s classroom Halloween party and other school activities.
Sensory‑room isolation: During the October 28, 2022, Halloween party, the student remained in the “Sensory Room” because “the Principal, the Lead Teacher, and the Special Education Supervisor informed [the parent] that the Student was agitated that day and they felt it would not be a good idea” for him to attend the party.
Reduced school day and loss of physical education: November 10, 2022, the “School changed the Student’s behavioral plan to shorten his school day and discontinue his physical education class because it creates over stimulation and causes him to act out.”
The complainant argued these actions were discriminatory and denied her son a free appropriate public education (FAPE).
OCR’s Investigation
OCR looked at whether the district treated the student differently because of his disability and whether he was denied FAPE. Investigators reviewed the student’s IEP and amendments, policies governing use of the Sensory Room, daily schedules, and meeting notes. They also interviewed the parent, the district’s supervisor of special education, and the school principal.
After examining the evidence, OCR determined there was enough proof of discrimination in one allegation but not in the others.
Key Facts of the Case
OCR’s letter provides a detailed timeline of the student’s school year and the events leading up to the complaint:
August 11, 2022, the students IEP was developed. It states that the student “may participate in any extracurricular and nonacademic activities for which he is qualified at the discretion of his parents as long as all district and school rules are followed.”
Early 2022‑23 school year: The student experienced behavior incidents related to his disability.
September 9, 2022: the student’s “IEP team held a manifestation determination meeting and determined that the Student’s behavior was a manifestation of his disability.”
September 22, 2022: The student’s special‑education class was scheduled to attend a school‑wide event. The parent volunteered at the event to help with her student, but noticed her son never arrived. She later learned that the principal “decided it would be “too hard on [Student]” to attend the event and decided to not allow the Student or his class to attend the event.”
Some staff later suggested the decision was made to avoid overstimulating him. The parent denied ever requesting that her son be kept from the event and said the school did not offer an alternative activity. “The Counselor further stated that the Student’s class had a substitute teacher that day, and that the Counselor initially instructed the teacher to “hold the kids from the water day event” because she was concerned about following the Complainant’s directions concerning the Student being overly excited. The Counselor stated that her intention was to get back with the substitute teacher later that morning to discuss the situation further, but that she did not do so until 2:00 PM when the Complainant attempted to pick up the Student from his class to attend the event. The Counselor stated that she spoke with the Complainant later that same day, acknowledging the oversight, and that the Complainant was kind and understanding during their conversation.”
October 25–26, 2022: In response to ongoing behavior incidents, the district held another manifestation determination and an IEP meeting. During the 25 October meeting the team amended the IEP to exclude the student from all extracurricular and school‑wide activities. The parent objected to this change. The next day, the district amended the IEP again to state that the student could participate in extracurricular activities and school‑wide events “with supervision”
October 28, 2022: The student was initially permitted to attend his brother’s in‑class Halloween party. When staff observed that he was agitated and had multiple aggressive outbursts, they decided he should remain in the Sensory Room for more than an hour during the party.
November 10, 2022: After continued incidents, the IEP team held a meeting and decided to shorten the student’s school day and to abbreviate his physical‑education class and move it to the end of the day.
The parent disagreed and later placed the student in a homebound program for part of the school day.
OCR’s Conclusions
OCR found that excluding the student from the September 22 event amounted to disability‑based discrimination. He had not misbehaved that day, and the district lacked evidence that he posed a safety risk. Under Section 504 of the Rehabilitation Act, schools cannot bar a student with a disability from activities unless necessary to provide equal opportunity or ensure safety. In this instance, OCR concluded the exclusion was unjustified.
For the Halloween party and sensory‑room use, OCR determined there was insufficient evidence of discrimination. The student was placed in the Sensory Room following behavior issues, consistent with his IEP, and remained under adult supervision. Likewise, OCR found the decision to shorten his school day and adjust his physical‑education schedule did not violate civil‑rights laws because it was based on specialist recommendations and the parent was offered procedural safeguards. Disputes over educational decisions are generally addressed through special‑education due process rather than OCR enforcement.
Remedy and Resolution Agreement
To address the discriminatory exclusion from the September 22 event, the district entered into a Resolution Agreement with OCR. Key provisions include:
“Training:
“Within 60 days of the execution of this Agreement, the District will provide Section 504 and Title II training to District faculty, staff, and administrators who have responsibility for coordinating, managing or providing students with non-academic and/or extracurricular services and activities. The training will emphasize that the District shall provide non-academic and extracurricular services and activities in such a manner as is necessary to afford students with disabilities an equal opportunity for participation in such services and activities. The training will also cover the general prohibition of different treatment on the basis of disability.
“Reporting Requirement:
“Within fifteen (15) days of the completion of the training described above, the District will provide OCR with the date(s) of the training session(s), the title and credentials of the trainer(s), a copy of the materials used in the training, and signed and dated sign-in sheets that include the name of staff members and their titles who attended the training sessions. The District will also provide its alternate plans to provide the training to District faculty, staff, and administrators who were unable to attend the scheduled training session(s).”
Final Words
This case underscores several important principles for school districts and families navigating special‑education services:
Equal access matters. Students with disabilities have the right to participate in school events and activities. Excluding a child because of disability‑related behaviors is discriminatory unless there is clear, individualized evidence that it is necessary for safety.
Parents have a voice. Families should be involved in IEP decisions and can challenge changes they believe are inappropriate. When disagreements arise, due process hearings provide a formal avenue for resolution.
Training is essential. Staff who supervise non‑academic activities need training on accommodating students with disabilities and avoiding assumptions about behavior.
Documentation protects everyone. Keeping thorough records of IEP meetings, behavioral plans, and decisions helps ensure student rights are respected and can support the district if a complaint arises.