Briscoe v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedMarch 31, 2024
DocketCivil Action No. 2022-3365
StatusPublished

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Briscoe v. District of Columbia, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JENNIFER BRISCOE, Guardian of the Minor Child K.B., Plaintiff, Civil Action No. 22-3365 (CKK) v. DISTRICT OF COLUMBIA, Defendant.

MEMORANDUM OPINION (March 31, 2024)

On behalf of the minor child K.B., and pursuant to the Individuals with Disabilities

Education Act (“IDEA”), Plaintiff Jennifer Briscoe (“Plaintiff”), filed this action against the

District of Columbia (the “District”) to challenge an August 29, 2022 Hearing Officer’s

Determination (“HOD”) that dismissed her administrative due process claim filed against the

District of Columbia Public Schools (“DCPS”). In that HOD, the Independent Hearing Officer

(“IHO”) concluded that: (1) DCPS timely provided Plaintiff with an authorization for her

requested independent educational evaluation (“IEE”); (2) Plaintiff failed to demonstrate that

DCPS’s December 2020 reevaluation of K.B. was inadequate; and (3) DCPS committed a

procedural violation related to the provision of K.B.’s educational records that did not amount to

a substantive denial of free appropriate public education (“FAPE”). See August 29, 2022 HOD,

ECF No. 13-1, at 4-24. DCPS was directed, however, to provide a list of student documents that are

maintained in the Special Education Database (“SEDS”). Id. at 17.

The parties have filed cross motions for summary judgment regarding that August 29,

2022 HOD. In her Points and Authorities in support of her Motion for Summary Judgment,

Plaintiff claims that: (1) DCPS unnecessarily delayed its response to Plaintiff’s request for an

1 IEE; (2) DCPS refused to authorize a sufficient IEE, which led to a substantive violation of the

IDEA; (3) DCPS failed to prove the 2020-2021 reevaluation was appropriate; (4) the IHO erred

in finding that DCPS’s failure to provide a “SEDS Document Index” was not a substantive denial

of FAPE; and (5) DCPS has not complied with the IHO’s Order to provide the “SEDS Document

Index.” See generally Pl.’s P&A, ECF No. 15-1. Those five arguments will be addressed

herein.

In response thereto, the District asserts that Plaintiff has neither established a denial of

FAPE nor that the IHO erred in his decision, which is “entitled to deference because it is

supported by substantial evidence and is in accordance with law.” Defendant’s Cross Motion for

Summary Judgment, ECF No. 16, at 4. Furthermore, the District contends that “DCPS complied

with the HOD’s remedial order.” Id. Upon review of the two motions for summary judgment

and the record herein, for the reasons set forth in detail in this Memorandum Opinion, the Court

finds that Plaintiff’s [15] Motion for Summary Judgment shall be DENIED and Defendant’s [16]

Cross Motion for Summary Judgment shall be GRANTED.1 A separate Order accompanies this

Memorandum Opinion.

I. BACKGROUND

A. Statutory Framework

The IDEA was enacted to “ensure that all children with disabilities have available to them

1 In connection with this Memorandum Opinion, the Court considered: (1) the Administrative Record (“AR”), ECF No. 13-1 [indexed at ECF No. 13]; (2) Plaintiff’s’ [15] Motion for Summary Judgment (“Pl.’s MSJ”), Plaintiff’s [15-1] Points and Authorities in support thereof (“Pl.’s P & A”), and the exhibit attached thereto; (3) Defendant’s [16] [consolidated] Opposition to the Motion for Summary Judgment and Cross Motion for Summary Judgment (“Def.’s CMSJ”); (4) Plaintiff’s [20] [consolidated] Opposition to Defendant’s Cross Motion and Reply in support of Motion (“Pl.’s Reply”); and (5) Defendant’s [22] Reply in support of Cross Motion (“Def.’s Reply”). In an exercise of its discretion, the Court finds that holding oral argument in this action would not be of assistance in rendering a decision. See LCvR 7(f).

2 a free appropriate public education (“FAPE”) that emphasizes special education and related

services designed to meet their unique needs and prepare them for further education, employment,

and independent living.” M.G. v. District of Columbia, 246 F. Supp. 3d 1, 7 (D.D.C. 2017) (citing

20 U.S.C. § 1400(d)(1)(A)), see also Boose v. District of Columbia, 786 F.3d 1054, 1056 (D.C.

Cir. 2015). Once a child is identified as disabled, the school district must convene a meeting of a

multi-disciplinary team to develop an individualized education program (“IEP”) for the student.

See 20 U.S.C. § 1414 (d)(2)(A). The IEP “is the centerpiece of the statute’s education delivery

system for disabled children[.]” Endrew F. ex rel. Joseph F. v. Douglas Cty. Sch. Dist. RE-1, 137

S. Ct. 988, 994 (2017) (citation omitted). The IDEA requires that a school system “offer an IEP

that is reasonably calculated to enable a [disabled student] to make progress in light of the child’s

circumstances.” Id. at 999. Once the IEP is developed, the school system must provide an

appropriate educational placement that comports with the IEP.

The IDEA and accompanying regulations provide that once a child is determined to have a

disability, a reevaluation is required to determine whether the child continues to present with a

disability and that the child shall be assessed in all areas of suspected disability during this

reevaluation. 34 CFR 300.304(c)(4). The reevaluation shall occur if the parent requests a

reevaluation. 34 CFR 300.303(a)(2). The reevaluation must occur at least every 3 years unless

the parent and the public agency agree that a reevaluation is unnecessary. 34 CFR 300.303(b)(2).

The reevaluation is comprised of a variety of tools, including, inter alia: (1) assessments tailored

to assess specific areas of educational need; (2) review of existing data; (3) classroom-based

assessment; (4) observations by teachers and related service providers; (5) input from the parents.

34 CFR 300.304(b)(2). Pursuant to 34 CFR 300.502(b)(1), “[a] parent has the right to an

independent educational evaluation [“IEE”] at public expense if the parent disagrees with an

3 evaluation obtained by the public agency.” After the parent requests an IEE, the school system

has two choices: “(i) [f]ile a due process complaint to request a hearing to show that its evaluation

is appropriate; or (ii) [e]nsure an independent educational evaluation is provided at public

expense.” 34 CFR 300.502(b)(2). If the hearing officer finds that the evaluation comports with

the requirements of the IDEA for an initial evaluation or reevaluation, the parent is not entitled to

an independent educational evaluation at public expense.

B. Factual History

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