In the 1993 case Florence County School District Four v. Shannon Carter, a minor represented by her father Emory D. Carter, the U.S Supreme Court ruled in favor of Shannon Carter's right to receive reimbursement for private school tuition from her public school district under the Individuals with Disabilities Education Act (IDEA). The court held that if a public school fails to provide an appropriate education and parents unilaterally place their child in a private facility which meets IDEA requirements, they are entitled to be reimbursed for associated costs. This decision came after Shannon was diagnosed with dyslexia and other learning disabilities but did not make significant progress despite special education services provided by her public high school. Her parents then enrolled her at Trident Academy, where she made substantial academic improvement; however, when they sought reimbursement from the local educational agency for this expense arguing it failed its duty under IDEA, both lower courts denied their claim leading them to appeal successfully before the Supreme Court.

In the dissenting opinion for Florence County School District Four v. Shannon Carter, Justice Blackmun argued that while he agreed with the majority's interpretation of the Individuals with Disabilities Education Act (IDEA), he disagreed on how it should be applied in this case. He believed that parents who unilaterally place their child in a private school without consent or referral from public authorities should not automatically receive reimbursement for tuition costs under IDEA. Instead, they should only be reimbursed if they can prove that public schools failed to provide an appropriate education and no suitable public alternatives were available. In his view, allowing automatic reimbursement could potentially lead to financial abuse by parents seeking expensive private educations at taxpayer expense and undermine efforts to improve special education within public schools.