child's IEP in some fashion); Rome Sch. Comm., 247 F.3d at 33 (issue was "extent of [the already eligible child's] needs for behavior management services,” and whether such services must be provided to child in IEP. to address behavior spilling over into school). While I can glean some guidance as to "need” from these cases, the fact that those children were already receiving services as eligible special education students makes the analysis somewhat different. Further, even in cases where eligibility is the predicate issue, courts do not engage in extended analysis of the differences between an ordinary understanding of "need,” as used by many parents or experts, and the statutory meaning assigned by the IDEA. See, e.g., Yankton Sch. Dist. v. Schramm, 93 F.33 1369, 1374 (8th Cir.1996) (<HOLDING>); but see Garda, supra, at 499-501 (stating
holding that an attorneys cause for services rendered over a period of time accrued when his services had been completely performed holding evidence of apparent authority insufficient where patient sought services of particular doctor rather than services of hospital generally holding that child who received services that school deemed 504 accommodations was ideaeligible because services rose to the level of specially designed instruction without analysis of need holding that plaintiff who provided similar services which were arguably attendant care services under state law fell within the exemption recognizing that generally services that benefit debtor are services that facilitate completion of a case