Metropolitan School District v. Davila
United States Court of Appeals for the Seventh Circuit
969 F.2d 485 (1992)
Robert Davila (defendant), Secretary of the Department of Education, issued a letter interpreting Part B of the Individuals with Disabilities Education Act (IDEA). The letter was never published in the Federal Register or subjected to public notice and comment. The Metropolitan School District of Wayne Township (plaintiff) sued on behalf of itself and similarly situated school districts, arguing the letter's interpretation imposed a large financial burden on districts and should have gone through notice-and-comment rulemaking under the Administrative Procedure Act (APA). The district court agreed, ruling the letter was a legislative rule subject to APA procedures, and granted summary judgment for the School District.
Whether the APA's notice-and-comment requirements apply to an agency rule that simply states the agency's understanding of what an existing statute means.