Larry P. v. Riles
{{Use mdy dates|date=September 2023}}
{{Infobox court case
|name=Larry P. v. Riles
|court=United States District Court for the Northern District of California
|citations={{cite court|vol=495|reporter=F.Supp.|opinion=926|url=https://law.justia.com/cases/federal/district-courts/FSupp/495/926/2007878/}}
|full name=LARRY P., by his Guardian ad litem, LUCILLE P., et al. v. Wilson RILES, Superintendent of Public Instruction for the State of California, et al.
|start date={{start date|1971|11|23}}
|ArgueDate={{start date|1977|10|11}}
|date decided={{start date|1979|10|16}}
|judges=Robert Francis Peckham
}}
Larry P. v. Riles is a California court case in which the court held that IQ tests could not be used to place African-American students in special education classes.
Five African-American children had been placed in special classes for the "educable mentally retarded", based on low IQ test scores. Judge Robert F. Peckham ruled that they had been wrongly placed.
Background
The case was filed by the National Association for the Advancement of Colored People (NAACP) Legal Defense fund. "Larry P." was one of the children, real name Darryl Lester.{{cite news |last1=Romney |first1=Lee |title=A Landmark Lawsuit Aimed to Fix Special Ed for California's Black Students. It Didn't. |url=https://www.kqed.org/news/11781032/a-landmark-lawsuit-aimed-to-fix-special-ed-for-californias-black-students-it-didnt |access-date=13 March 2023 |publisher=KQED |date=18 October 2019 |language=en-us}} Wilson Riles was the California State Superintendent of Public Instruction.
District court ruling
The case was initially filed in 1971, as a class-action on behalf of six African-American students in the San Francisco School District. On June 20, 1972, a preliminary injunction was issued forbidding the use of IQ tests by the San Francisco School District to place African-American students in special education. The injunction was upheld on appeal in 1974.
A trial on the merits was delayed because of the implementation of the 1974 master plan, but the case eventually proceeded to trial in October 1977.
The final ruling was issued by United States District Court for the Northern District of California in 1979.{{cite web |title=Larry P. v. Riles, 495 F. Supp. 926 (N.D. Cal. 1979) |url=https://law.justia.com/cases/federal/district-courts/FSupp/495/926/2007878/ |website=Justia Law |access-date=13 March 2023 |language=en}}
Appeals court
{{Infobox COA case
|name=Larry P. v. Riles
|court=United States Court of Appeals for the Ninth Circuit
|citations={{cite court|vol=793|reporter=F.2d|opinion=969|url=https://law.resource.org/pub/us/case/reporter/F2/793/793.F2d.969.80-4027.html}}
|prior actions={{cite court|vol=495|reporter=F.Supp.|opinion=926}}
|full name=LARRY P., by his Guardian ad litem, LUCILLE P.; M.S., by his Guardian ad litem, Joyce S.; M.J., by his Guardian ad litem, Mary H.; Sylvia M., by her Guardian at litem, Sylvia W.; J.L., by his Guardian ad litem, Selena F., Plaintiffs-Appellees, v. Wilson RILES, Superintendent of Public Instruction for the State of California, Defendant-Appellant, Henry P. Gunderson, et al., Defendants.
|ArgueDate={{start date|1981|11|12}}
|date decided={{start date|1984|01|23}}
|judges=Otto Richard Skopil Jr., Cecil F. Poole, William Benner Enright
}}
The primary ruling was upheld on appeal to the 9th circuit in 1984.{{cite web |title=Larry P., by His Guardian Ad Litem, Lucille P. et al. v. Wilson Riles, et al., Defendants, 793 F.2d 969 (9th Cir. 1986) |url=https://law.justia.com/cases/federal/appellate-courts/F2/793/969/119286/ |website=Justia Law |access-date=13 March 2023 |language=en}}
The appeals court, in 1984, further banned the use of IQ tests on African-American children.{{cite web |title=What is the Larry P. v. Riles case? How did it originate? |url=https://serr.disabilityrightsca.org/serr-manual/chapter-2-information-on-evaluations-assessments/2-45-what-is-the-larry-p-v-riles-case-how-did-it-originate/ |website=SERR – Special Education Rights and Responsibilities |publisher=Disability Rights California |access-date=13 March 2023 |language=en}}{{dubious|date=June 2024}}
Later interpretations
The case has been described as "arguably the most well-known legal decision related to cognitive assessment".{{cite journal |last1=Woods |first1=Isaac L. |last2=Graves |first2=Scott L. |title=The Fortieth Anniversary of Larry P. V. Riles: Cognitive Assessment and Black Children |journal=Contemporary School Psychology |date=1 June 2021 |volume=25 |issue=2 |pages=137–139 |doi=10.1007/s40688-021-00373-6 |language=en |issn=2161-1505|doi-access=free }}
In a later case, Crawford v. Honig, African-American children were permitted to take IQ tests if their parents permitted it.{{cite web |title=Demond Crawford v Bill Honig. 37 F.3d 485 (9th Cir. 1995) |url=https://law.justia.com/cases/federal/appellate-courts/F3/37/485/509223/ |website=Justia Law |access-date=13 March 2023}}{{cite news |last1=Walsh |first1=Mark |title=Appeals Court Upholds Black Parents' Rights To Learn Child's I.Q. |url=https://www.edweek.org/education/appeals-court-upholds-black-parents-rights-to-learn-childs-i-q/1994/10 |access-date=13 March 2023 |work=Education Week |date=12 October 1994 |language=en}}{{cite news |last1=Mathews |first1=Jay |title=IQ tests restricted by race |url=https://www.washingtonpost.com/archive/politics/1987/07/06/iq-tests-restricted-by-race/9c85a956-4ec9-4dfa-8191-70af9c1ff0cb/ |access-date=13 March 2023 |newspaper=Washington Post |date=6 July 1987}}
After Crawford v. Honig, the California Department of Education issued memoranda in 1992 and 1997 stating that the prohibition on IQ tests for African-American students would still be followed.{{cite web |title=CASP's Response to CDE's Memorandum on Special Education of African American Students |url=https://casponline.org/pdfs/resource-papers/Updated%20Larry%20P.%20Guidance%20Paper%2010-10-23.pdf |publisher=California Association of School Psychologists |access-date=4 June 2024}}