In 2007, the Supreme Court heard a case that involved the question of whether a school district could be required to reimburse parents who unilaterally placed their child in private school when the child had not previously received special education and related services in a public institution ("Board of Education v. Tom F."). The Court's 4-4 ruling in that case was not definite, however, and as a result, it left in place a split on the issue in the federal circuit courts. Now the Court has handed down a ruling in a similar case, "Forest Grove School District v. T. A." (2009), but this time around, the result for schools is clear-cut. The law of the land--as it applies to the question presented in this case--is that parents may receive reimbursement from their public school districts after placing their children in private schools that meet their needs for special education, even if that child never received special education services in the public schools. Although the Court has clarified that such reimbursements are authorized under IDEA, it has also outlined a set of criteria that must be met before such reimbursement could come to fruition. Specifically, a parent who makes such a claim for tuition reimbursement would have to prove that the school district failed to make a free and appropriate public education (FAPE) available to the student in a timely manner and that the private placement is appropriate. Such conclusions would have to be arrived at in a court of law.