Spielberg ex rel. Spielberg v. Henrico County Public Schools

ERVIN, Circuit Judge:

Jonathan Spielberg is a severely retarded nineteen year old resident of Henrico County, Virginia. Since 1977, the Henrico County Public Schools have paid the full cost of his education at the Melmark School (“Melmark”), a residential facility in Pennsylvania, under the Education of All Handicapped Children Act (“EHA”), 20 U.S.C. § 1401, et seq. In March 1985, the county initiated a reevaluation of Jonathan’s placement which concluded that he could be educated at a local school. His parents appealed that decision, seeking to continue his institutional placement. The…