Dyslexia in the Federal Courts: What Recent Cases Mean for Families

A Tennessee student with dyslexia graduated from high school with a 3.4 GPA, but he couldn’t read. In 2025, a federal appeals court ruled that his school had failed him, and it ordered 888 hours of reading instruction to make up for it.

That case is one of several recent federal decisions that show what schools owe students with dyslexia, and where the law stops. For parents, these rulings help you know what to ask for. For teachers, evaluators and advocates, they show what courts expect to see in a child’s file.

The legal basics

Three federal laws protect students with dyslexia:

• The Individuals with Disabilities Education Act (IDEA) requires public schools to find and evaluate children who may have a disability (“Child Find”). Eligible students must receive a free appropriate public education (FAPE) through an Individualized Education Program (IEP). Dyslexia usually falls under the IDEA category “specific learning disability.”
• Section 504 of the Rehabilitation Act bars disability discrimination by schools that receive federal funds. Many students with dyslexia have a 504 plan that provides accommodations.
• The Americans with Disabilities Act (ADA) gives similar anti-discrimination protection in public schools.

Under the Supreme Court’s 2017 decision in Endrew F., an IEP must be “reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances.” The cases below apply that standard to reading.

Four federal cases to know

Accommodations can’t replace reading instruction

William A. v. Clarksville-Montgomery County School System, 127 F.4th 656 (6th Cir. Feb. 3, 2025)

William had an IEP from fifth grade on. His reading fluency stayed below the 10th percentile, and he never met a fluency goal. His accommodations kept growing: extra time, text-to-speech, and software and AI tools that “simply did the work for him.” One teacher wrote to administrators, “This kid can’t read.” He still earned passing grades and graduated.

The Sixth Circuit held that he was denied a FAPE. The IDEA doesn’t guarantee that every child learns to read. But when a child can learn to read and the IEP “does not aim to help him overcome his particular obstacles,” the IEP fails. Passing grades and promotion from grade to grade did not prove otherwise. The court upheld 888 hours of compensatory tutoring from a trained reading interventionist.

Schools still choose the teaching method

Crofts v. Issaquah School District No. 411, 22 F.4th 1048 (9th Cir. 2022)

Parents asked the district to use the Orton-Gillingham approach and to label their daughter’s disability “dyslexia.” The district declined both requests. The Ninth Circuit sided with the district. An evaluation under “specific learning disability” was enough, because it tested the reading and writing skills dyslexia affects. Parents can’t require a particular method unless they show the child needs it to receive a FAPE, and this student was making progress without it.

Child Find has limits

A.P. v. Pearland Independent School District, No. 25-40010 (5th Cir. Nov. 10, 2025)

A ninth grader missed 24 to 29 days in each class and failed five of seven courses. Her parents later raised dyslexia and requested a hearing, but refused consent for the district’s evaluation. A private evaluation found no dyslexia. The Fifth Circuit ruled for the district. Absences and poor grades alone didn’t trigger Child Find, and the district responded promptly once dyslexia was raised. Refusing the school’s evaluation weighed against the family.

A lower bar for discrimination claims

A.J.T. v. Osseo Area Schools, No. 24-249 (U.S. June 12, 2025)

This unanimous Supreme Court case involved a student with epilepsy, not dyslexia, but it affects every student with a disability. Some courts had required students suing under the ADA or Section 504 to prove the school acted in “bad faith” or with “gross misjudgment.” The Court rejected that rule. Students now face the same standards as anyone else bringing a disability discrimination claim. Families of children with dyslexia may find these claims easier to bring alongside an IDEA case.

What this means for parents

• Ask whether your child is learning to read, not just passing. Good grades can hide a reading gap when accommodations do the work. Ask for reading scores and progress on each IEP goal.
• Look for instruction, not only accommodations. Extra time and text-to-speech help children access class. They don’t teach decoding. The IEP should include both.
• Put concerns in writing early. Schools must act once they have reason to suspect a disability. A written request for an evaluation starts the clock.
• Consent to the school’s evaluation. Refusing it can weaken your case later. You can still request an independent evaluation if you disagree with the results.
• Focus on what your child needs, not a brand name. Courts rarely order a specific program. Show why your child needs a certain kind of instruction, such as explicit phonics, based on their data.

What this means for professionals

• Track foundational skills, not just grades. Measure decoding, phonemic awareness and fluency, and change course when goals are missed year after year.
• Check whether accommodations hide the problem. If assistive tools complete the reading for a student, the IEP should still teach the skill.
• Evaluate the areas dyslexia affects. The word “dyslexia” isn’t required, but the evaluation must test reading and writing skills thoroughly.
• Document your reasons for choosing a method. Schools may choose their method, but the record should show it’s reasonably calculated for this student’s progress.
• Respond quickly to a parent’s concerns. In P., a prompt response to the dyslexia concern helped the district.
• Expect more ADA and Section 504 claims. After J.T., families no longer have to show bad faith to bring these claims.

This article is for general information and is not legal advice. Every child’s situation is different. If you have concerns about your child’s education, talk with a qualified special education attorney or advocate.

Sources

• William A. v. Clarksville-Montgomery County School System, Sixth Circuit opinion (Feb. 3, 2025)
• CADRE, Top Ten in 2025: A Review of Relevant Special Education Case Law
• P. v. Pearland Independent School District, Fifth Circuit opinion (Nov. 10, 2025)
• Perry A. Zirkel, Special Education Legal Update (Dec. 2025)
• Liebert Cassidy Whitmore, summary of Crofts v. Issaquah School District
• ACSA EdCal, Ninth Circuit holds that specific learning disability evaluation was appropriate
• Faegre Drinker, Supreme Court decides A.J.T. v. Osseo Area Schools (June 2025)