Brandon A. v. NHDOE

2001 DNH 147
CourtDistrict Court, D. New Hampshire
DecidedAugust 8, 2001
DocketCV-00-25-B
StatusPublished

This text of 2001 DNH 147 (Brandon A. v. NHDOE) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brandon A. v. NHDOE, 2001 DNH 147 (D.N.H. 2001).

Opinion

Brandon A. v. NHDOE CV-00-25-B 08/08/01 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Brandon A . , by and through his parent and next best friend, David A . , on behalf of himself and all others similarly situated

v. Civil No. 00-025-B Opinion No. 2001 DNH 147 Nicholas Donahue, in his Official Capacity as Commissioner of The New Hampshire Department of Education

MEMORANDUM AND ORDER

Brandon A. is a student with learning disabilities who is

entitled to a free and appropriate public education pursuant to

the Individuals with Disabilities Education Act ("IDEA" ) , 20

U.S.C. § 1400, et seq. Brandon has brought a class action

complaint for declaratory and injunctive relief against the

Commissioner of the New Hampshire Department of Education

("NHDOE"), alleging that Brandon and his fellow class members

have been denied their right under the IDEA to a due process

hearing and a decision within 45 days after a request for a

hearing is filed with the NHDOE. The Commissioner has moved to

dismiss the complaint alleging that Brandon did not have standing when he filed suit and that his claim is moot because he received

the hearing he requested.

I. BACKGROUND1

A. Brandon A.

Brandon is a fourteen year-old educationally disabled

student in the Epsom School District (the "School District"). He

is currently attending the Wreath School, a residential

educational facility in Pike, New Hampshire.

On July 1, 1999, Brandon's father requested a due process

hearing challenging the School District's refusal to provide

Brandon with an extended school-year program in a therapeutic

setting. He also alleged that the School District failed to

identify Brandon as "seriously emotionally disturbed" and to

create an individualized education program ("IEP") that addressed

his emotional disability.

In response to the request, the NHDOE assigned Attorney Siff

to conduct a mediation session with the parties on July 22, 1999,

and to preside at their hearing on August 16, 1999. The parties

1 Except where noted, I take the facts from the Second Amended Complaint, Doc. No. 44, and the parties' briefs.

- 2 - unsuccessfully attempted mediation on two occasions. Because

Attorney Siff conducted the mediation sessions, he recused

himself from sitting as the hearing officer.

On July 30, 1999, Attorney John Lebrun notified the parties

that he would preside as the hearing officer. At that time,

Lebrun scheduled a prehearing conference for August 20, 1999,

thereby canceling the August 16, 1999 hearing.

In a letter dated July 30, 1999, the School District

requested that Brandon's father sign a release covering any and

all records and oral information in the possession of various

psychiatric hospitals, counseling services, and other

organizations that provided services to Brandon. Brandon's

father objected to the School District's request.

At the prehearing conference on August 20, 1999, the School

District filed a motion to compel Brandon's father to sign the

release. Brandon's father countered with a motion for a

protective order arguing that the records were not essential

because the issues he had raised could be resolved based on the

records in Brandon's existing educational file. He further

objected to signing the release on the grounds that such broad

- 3 - discovery would frustrate the IDEA's requirement that a hearing

be concluded and a final decision rendered within 45 days of the

receipt of a request for a hearing.

At the August 20, 1999 prehearing conference, the hearing

officer recused himself because he had previously represented

Brandon in an involuntary emergency admission proceeding. The

NHDOE reassigned the case to Hearing Officer Jeanne Kincaid

("Officer Kincaid"). On August 26, 1999, the parties resubmitted

their motions regarding discovery.

At the second prehearing conference held on September 2,

1999, Officer Kincaid informed the parties that if Brandon's

father did not sign the release, she would consider issuing an

order compelling him to do so. Over Brandon's father's

objection. Officer Kincaid also granted an extension of the 45-

day requirement for issuing a decision because of the change in

hearing officers and the need to secure documentation from

outside agencies.

On September 10, 1999, Officer Kincaid issued a "Discovery

Order" requiring Brandon's father to sign the release. When he

did not comply with the discovery request. Officer Kincaid

dismissed the case without prejudice.

- 4 - Brandon's father then filed suit in this Court, pursuant to

the IDEA, 20 U.S.C. § 14 1 5 (i)(2), appealing Officer Kincaid's

decision requiring that he sign a release and dismissing

Brandon's case. He also brought a claim on behalf of his son and

all others similarly situated, pursuant to 42 U.S.C. § 1983, to

enforce their right to a timely impartial due process hearing and

decision under the IDEA, 20 U.S.C. § 1415(f).

After a hearing in this court on October 26, 2000, the

parties agreed that the court should remand Brandon's individual

claims to Officer Kincaid. Officer Kincaid held a two-day

hearing on December 19 and 22, 2000, and issued a decision on

January 2, 2001. She awarded Brandon three months of

compensatory education and ordered the School District to revise

its evaluation and meeting procedures to comply with recent

amendments to the IDEA.

Brandon filed a second amended complaint on November 22,

2000, alleging that the NHDOE's system of hearings denies

students their right to a timely impartial due process hearing

and corresponding decision under the IDEA, 20 U.S.C. § 1415(f).

B. Class Allegations

From 1989 to 1999, the NHDOE received about 80 requests per

- 5 - year for due process hearings.2 Of the 80 requests, a decision

was issued in an average of 15.82 cases per year. The remaining

cases settled, were resolved through mediation, or were

withdrawn. Since 1989, only 11 out of the 171 hearings conducted

were decided within 45 days. Furthermore, in 96 out of the 171

hearings held since 1989, the hearing officers took over 100 days

to conclude the hearing and reach a decision.

In addition, in 1994, the Office of Special Education

Programs determined that the NHDOE was not complying with the 45-

day requirement. See Tr. of Oral Argument, Oct. 26, 2000, Doc.

No. 41, at 44. A due process hearing is considered to be in

compliance when the hearing and decision is rendered within the

45-day limit or when the hearing officer provides a written order

specifically granting a party's request for an extension to the

45-day limit. I d . at 42.

The NHDOE allegedly causes delays in the hearing process by

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