In the 1984 case of School Committee of the Town of Burlington, Massachusetts v. Department of Education of Massachusetts, the U.S Supreme Court ruled in favor of parents who unilaterally changed their child's placement under the Individuals with Disabilities Education Act (IDEA). The court held that if a court ultimately determines that a school failed to provide an appropriate education and that private schooling was suitable for the student, then reimbursement is required. This decision allows parents to seek reimbursement from public schools for expenses incurred while providing special education services privately when they believe public schools are not adequately meeting their children’s needs. The ruling emphasized on ensuring substantive rights provided by IDEA and protecting students against any procedural violations which might result in loss or denial of educational benefits.

In the dissenting opinion for the case of School Committee of Burlington, Massachusetts v. Department of Education et al., Justice White disagreed with the majority's interpretation that parents could be reimbursed for private school tuition under the Education for All Handicapped Children Act (EAHCA). He argued that this was not what Congress intended when they passed EAHCA and it would place an undue financial burden on public schools. Furthermore, he contended that allowing such reimbursements would encourage parents to unilaterally remove their children from public schools without giving them a chance to provide appropriate services or accommodations. This, according to him, undermines one of EAHCA’s main objectives: ensuring disabled students receive free appropriate education in public institutions whenever possible.