Sixth Circuit Court Rules in Favor of Dyslexic Student’s Right to Effective Reading Instruction
Understanding Education and Dyslexia
By Rebecca O’Malley, Esq.
Dyslexia impacts between 5-10% of the U.S. population. School districts are thus required to provide an appropriate education to students with this relatively common learning disorder. However, the particular type of instruction required to help many dyslexic students learn how to read can be time-consuming and costly.
For this reason, it can be challenging for parents to convince their IEP team that specialized reading instruction is necessary and cannot be substituted by more cost-limited accommodations and tutoring.
Role of School Districts in Educating Students with Dyslexia
It’s true that California has made recent efforts to begin screening for dyslexia more regularly and at a younger age. Yet, many of our clients report that it can still be difficult to collaborate effectively with their IEP team. This includes parents’ difficulty in obtaining instruction that actually helps their students learn how to read.
Earlier this month, however, the Sixth Circuit Court of Appeals issued a decision that may provide such parents with additional support. The case, William A. v. Clarksville-Montgomery County School System, No. 24-5591 (6th Cir. 2025), addressed the school district’s obligation to provide instruction that actually permitted the student to learn how to read rather than simply providing accommodations that allowed him to advance from grade to grade without ever addressing his literacy challenges.
The Case of William A. and the Clarksville-Montgomery School System
William A. was a dyslexic student who graduated high school with a 3.4 grade-point average, even though he could neither read nor spell his own name.
When William enrolled in the Clarksville-Montgomery School System in fifth grade, the District determined that he had “a learning disability that impaired his skills in reading, writing, and math.” As a result, the District developed an IEP that provided William with speech therapy, six hours of weekly one-to-one instruction, and multiple accommodations. However, as William progressed through middle school, his IEP was rarely changed, even as he repeatedly failed to meet his reading fluency goals.
When William reached high school, his special education teacher informed school administrators that William could not read. Finally, in 11th grade, the school psychologist determined that William was dyslexic.
The District agreed to provide “additional accommodations, including the use of technology programs that read aloud printed text and helped him to write,” but the IEP did not include targeted reading instruction to address William’s specific needs. While these accommodations were perhaps well-meaning, they continually masked William’s inability to read.
Accommodating William’s Needs and Being Proactive
Accommodations and tools that make it easier to complete schoolwork do not help to develop the ability to read. The Court highlighted how William completed assignments—he dictated topics into speech-to-text software, used AI to generate papers, and pasted the results into his documents. These workarounds did not actually teach him to read.
Frustrated, William’s parents hired a private tutor, who used structured literacy methods focused on decoding and syllable recognition. With this approach, William made progress. His parents requested that the school continue this instruction, but the District refused, prompting the parents to file for due process.
At the hearing, specialists explained that reading instruction must start with foundational skills, like decoding, before advancing to fluency. They further noted: “At the foundation of a student’s ability to read lie basic skills like decoding and encoding—how letters make sounds, and how sounds make words. Until a student masters these basic skills, he cannot develop the advanced skills, like fluency, that were the focus of William’s IEP.”
The administrative law judge (ALJ) found that William could learn to read but needed a different instructional approach than what his IEP provided. Specifically, the Court noted that, unlike the instruction William had received in school, which focused on reading fluency, “[The specialized tutor] focused on more basic skills, like alphabetic sequencing and syllable recognition.” Thus, as a result of her instruction, “William advanced to the second step of a twelve-step program designed to help dyslexic persons learn to read.”
Administrative Law Judge and District Court Ruling
Both the ALJ and the District Court ruled that William’s IEPs were inadequate, finding that the IEPs “were not tailored to his circumstances because those plans focused on fluency while bypassing more foundational skills necessary for him to read.” As such, the school district was ordered to provide William with 888 hours of dyslexia tutoring from a trained reading interventionist.
The Sixth Circuit Court of Appeals affirmed the ruling, stating: “[W]hen a child is capable of learning to read, and his IEP does not aim to help him overcome his particular obstacles to doing so, that IEP does not provide him the ‘free appropriate public education‘ to which he is entitled.’”
A Future of Improved Education for Dyslexic Students
This decision provides a strong foundation for arguing that simply providing some individualized instruction and accommodations for dyslexic students may be insufficient if the program does not address the student’s foundational ability to read.
Parents of dyslexic students should, therefore, consider referencing this decision in their discussions with other members of the IEP team when seeking tailored instruction to address the underlying causes of their student’s reading challenges.
Although a decision by the Sixth Circuit Court of Appeals is not binding on administrative and federal courts in California, the decision will still undoubtedly be influential throughout the country since it comes from a federal appellate court.
Get Help with Your Child’s Individual Education Program
Understanding your child’s educational needs can be challenging, but you don’t have to figure things out alone. At Woodsmall Law Group, PC., our specialized attorneys focus on special education needs and help your family understand your legal rights.
If you would like to discuss how the William A. decision may be relevant to the development of your child’s individual education program, please feel free to speak with one of our skilled special education lawyers at our Southern California office. Call our law firm at (626) 440-0028 for more information—we’re always here to help.