Mark D. Evans


In Arizona State Board for Charter Schools v. U.S. Department of Education, the Ninth Circuit validated a U.S. Department of Education policy that for-profit charter schools are ineligible for federal funding under the Individuals with Disabilities Education Act and Title I of the Elementary and Secondary Education Act. That policy now threatens to chill the growth of charter schools in states that would have otherwise encouraged their expansion. This Note examines the details of the Ninth Circuit's decision, its effect on states that allow for-profit charter schools, and its impact on the charter school movement.