The case of Irving Independent School District v. Tatro revolved around the interpretation of the Education for All Handicapped Children Act (EAHCA). Amber Tatro, a student with spina bifida required clean intermittent catheterization (CIC) every few hours to prevent urinary tract infections and kidney damage. Her parents argued that under EAHCA, this service should be provided by school staff during school hours as it was necessary for her to attend school safely and comfortably. The Irving Independent School District disagreed, arguing that such services were medical in nature and not covered under EAHCA's "related services" clause which they believed only included supportive services like transportation or speech therapy. The Supreme Court ruled 9-0 in favor of the Tatros stating that CIC was indeed a related service because it could be performed by a layperson with minimal training rather than requiring a physician’s expertise. Therefore, schools are obligated to provide such support if needed for disabled students to participate in classroom activities without risking their health.

In the dissenting opinion for Irving Independent School District v. Tatro, Justice Burger argued that the majority's interpretation of "related services" under the Education for All Handicapped Children Act was overly broad and could lead to unreasonable demands on school resources. He contended that while schools should provide necessary medical services, they are not equipped or required to provide continuous one-on-one nursing care during school hours. He suggested that such extensive medical support falls outside a school’s responsibility and instead lies with parents or health agencies. Furthermore, he expressed concern about potential liability issues if non-medical personnel were tasked with performing complex medical procedures in an educational setting.