Even a condition that seems purely medical may trigger Child Find duties for school officials under the Individuals with Disabilities Education Act or Section 504 of the Rehabilitation Act, particularly if there were “warning signs” such as academic or disciplinary struggles, a federal appeals court has ruled.

The decision in Culley v. Cumberland Valley School District illustrates how some courts are looking at medical conditions as factors capable of shaping students’ lives and contributing to educational difficulties.

In the suit, the parents of a student with Crohn’s disease, whose academic and disciplinary performance “took significant turns for the worse” from seventh to 10th grade, claimed that their son should have been identified as a student with a disability.

After a disciplinary dispute that resulted in his expulsion, the parents filed suit claiming the district violated their son’s rights under the IDEA and Section 504.

According to the District’s 2014 Evaluation Report, the student was deemed ineligible for special education and related services. A special education Hearing Officer agreed that student was not eligible under the IDEA, finding that Crohn’s was a qualifying disability, but that the student did not require specially designed instruction.

But the courts took a different view. The Third Circuit described Crohn’s disease as “a painful, even debilitating, disease that affects the digestive tract.”

The three-judge panel suggested that knowledge of a Crohn’s diagnosis alone was enough to trigger the district’s Child Find duty under Section 504 to ensure that the student received “whatever accommodations he might require” for his Crohn’s disease.

By the time the student was exhibiting academic and disciplinary issues, the panel found, the district should have determined if those issues stemmed from his Crohn’s disease, for both 504 and IDEA Child Find purposes.

The ruling provides important guidance for school districts on the issue of drawing the line between “medical” and “educational.” Ultimately, the Third Circuit viewed the student’s disease of the digestive system as a “defining condition of [his] life” that was connected to his academic and disciplinary performance at school.

Seen through that lens, the appellate panel said it was critical for the district to investigate the potential link between the “warning signs” and the Crohn’s diagnosis, and that it was insufficient to conclude that the student did not require specially designed instruction.