183444P.pdf   03/02/2020  D. L.  v.  St. Louis City School District
   U.S. Court of Appeals Case No:  18-3444
                          and No:  18-3497
   U.S. District Court for the Eastern District of Missouri - St. Louis   
   [PUBLISHED] [Erickson, Author, with Melloy and Kobes, Circuit Judges] 
   Civil case - Individuals with Disabilities Education Act. The District's 
   jurisdictional challenge was without merit because the student was 
   enrolled in the City School District at the time the complaint was filed, 
   had not yet enrolled in a private school setting and his parents had 
   provided the school with notice; plaintiff sought compensation for past 
   obligations, rather than prospective relief, and his claims were not moot 
   because he no longer resided in the District; district court's 
   misstatement of the burden of proof was immaterial as it merely 
   incorrectly described a past proceeding and the court properly placed the 
   burden of proof and applied the correct standard of review in the 
   proceeding pending before it; the district court did not err in 
   determining the District had denied plaintiff and Free Appropriate Public 
   Education when it placed him at a school without direct occupational 
   therapy or a sensory diet plan to address his autism-related issues; the 
   district court erred in limiting its tuition reimbursement award based on 
   improvements the District had made to plaintiff's school as those 
   improvements were not communicated to plaintiff's parents; the limitation 
   of tuition reimbursement is reversed and the matter is remanded with 
   directions to award plaintiff full reimbursement for his attendance at a 
   private school.