AI & IEP’s
Technology, particularly artificial intelligence (AI), has significantly impacted every field, from healthcare to education, transforming how we work, learn, and communicate. In response to AI's growing role, the Tennessee legislature recently passed a law requiring school districts to implement policies governing the use of AI tools in education.
This shift toward incorporating AI in classrooms brings both opportunities and challenges, especially when it comes to students with disabilities. Under the IDEA, schools are required to provide “specifically designed instruction, at no cost to parents, to meet the unique needs of a child with a disability.” 20 U.S.C. § 1401(29). Additionally, the Supreme Court has stated that schools are required to provide more than a minimal education. More specifically the Court stated, "To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances." Endrew F. v. Douglas County School District (2017).
In a recent 6th Circuit decision, the Court cautioned districts to avoid using technology to mask disabilities rather than using technology to assist in direct instruction. William A v. Clarksville-Montgomery County School System, 6th Cir. (2025).
William A. v. Clarksville-Montgomery County School System
William A. was a student in the Clarksville-Montgomery County School System who, throughout his education, struggled significantly with reading. Diagnosed with dyslexia, William faced challenges in decoding words and building essential reading skills, which are critical for academic success. Despite these struggles, he graduated high school with a 3.4 G.P.A., though it was clear that he had not reached a level of proficiency in reading. In fact, the administrative law judge noted that William could not read or even spell his name.
William’s Individualized Education Plan (IEP) incorporated assistive technologies and accommodations such as reading software and extra time on assignments. The Court noted that the accommodations were designed to circumvent the goal, namely learning to read. Specifically, to write a paper, William would speak into ChatGPT, paste that to Grammarly, and then submit the results as his assignment.
William's IEPs focused on adapting to the environment around him rather than providing effective, targeted instruction to help him overcome his reading difficulties. In short, the 6th Circuit said that using technology as a walk-around to mask a disability is a denial of FAPE under IDEA.
Consequently, the court ordered CMCSS to provide 888 hours of compensatory dyslexia tutoring to remediate the shortcomings of his IEP. Lastly, they sent the case back to the lower court to determine if the district would pay the parent's attorney fees of $267,000.
The William A. v. Clarksville-Montgomery County School System case serves as an important reminder that technology in education should be used as a supportive tool, not a crutch. While AI tools and other educational technologies are making their way into classrooms across the country, they must be integrated into individualized teaching strategies rather than becoming a way to mask learning gaps.