C.M.E. v. Shoreline School District

CourtDistrict Court, W.D. Washington
DecidedJune 2, 2020
Docket2:19-cv-02019
StatusUnknown

This text of C.M.E. v. Shoreline School District (C.M.E. v. Shoreline School District) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
C.M.E. v. Shoreline School District, (W.D. Wash. 2020).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 5 AT SEATTLE 6 C.M.E. O/B/O W.P.B., 7 Plaintiff, CASE NO. 2:19-cv-02019-RAJ-BAT 8 v. ORDER DENYING MOTION TO 9 AMEND SHORELINE SCHOOL DISTRICT, 10 Defendant. 11

Before the Court is the motion to amend of Plaintiff C.M.E. (“Parent”). Dkt. 17. 12 Defendant Shoreline School District (“the District”) opposes Plaintiff’s motion. Dkt. 23.1 This 13 matter is an appeal of an administrative decision overriding Parent’s refusal to consent to an 14 initial evaluation of Student for special education services under the Individuals with Disabilities 15 Education Act (IDEA), 20 U.S.C. §§ 1400. Parent seeks to add claims under the Americans with 16 Disabilities Act of 1990 (ADA), 42 U.S.C. § 12101, and Section 504 of the Rehabilitation Act of 17 1973 (Rehabilitation Act), 29 U.S.C. § 794. For the reasons stated herein, the motion to amend is 18 denied. 19 BACKGROUND 20 Background information regarding this appeal is summarized in the administrative 21 decision appealed by Parent. Dkt. 11, Appendix A at page 5 (describing action as appeal of final 22

23 1 The Court originally granted the motion to amend but withdrew the order to properly consider the District’s response. See Dkt. 26 (motion to amend incorrectly noted). 1 administrative decision and identifying 20 U.S.C. § 1415 as the source of jurisdiction). This 2 appeal arises out of Parent’s refusal to consent to the District’s proposed initial evaluation of 3 Student for special education services. Dkt. #11, Appendix A at p. 3-4. Under the IDEA, if a 4 parent refuses to consent to an initial evaluation, the District may request a due process hearing 5 to pursue the initial evaluation. 20 U.S.C. § 1414(a)(1)(D)(ii). The District requested a due

6 process hearing and sought an order overriding Parent’s refusal to consent to its proposed initial 7 evaluation. Dkt. 11, Appendix A at p. 4. The District and Parent filed motions for summary 8 judgment. Id. The Office of Administrative Hearings granted the District’s motion for summary 9 judgment and denied Parent’s motion for summary judgment. Dkt. 11, Appendix A at p. 8. 10 Parent appealed by filing a civil action in King County Superior Court in accordance with 11 20 U.S.C. § 1415(i)(2). Dkt. 2, Exh. A at p. 1. The District removed the action to this Court 12 based on original subject matter jurisdiction. Parent filed a motion to remand this matter to 13 superior court, which the Court denied on April 21, 2020. Dkt. 15. On May 20, 2020, the Court 14 issued a schedule for the filing of briefs following the filing of the administrative record by the

15 OSPI, Administrative Resource Services. Dkt. 18. 16 DISCUSSION 17 Under Fed. R. Civ. P. 15(a)(2), “a party may amend its pleading only with the opposing 18 party’s written consent or the court’s leave.” Although this rule is applied with “extreme 19 liberality,” leave to amend may be denied “upon showing of bad faith, undue delay, futility, or 20 undue prejudice to the opposing party.” Chudacoff v. University Med. Center of Southern 21 Nevada, 649 F.3d 1143, 1152 (9th Cir. 2011). The court considers five factors in determining 22 whether leave to amend is appropriate: “(1) bad faith, (2) undue delay, (3) prejudice to the 23 opposing party, (4) futility of amendment; and (5) whether plaintiff has previously amended [his 1 or her] complaint.” Allen v. City of Beverly Hills, 911 F.2d 367, 373 (9th Cir. 1990). 2 The court need not consider all five factors, and “the consideration of prejudice to the 3 opposing party. . . carries the greatest weight.” Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 4 1048, 1052 (9th Cir. 2003). In the context of a motion to amend, prejudice means “‘undue 5 difficulty in prosecuting a lawsuit as a result of a change of tactics or theories on the part of the

6 other party.’” Wizards of the Coast LLC v. Cryptozoic Entm’t LLC, 309 F.R.D. 645, 652 (W.D. 7 Wash. 2015) (quoting Deakyne v. Cmmsrs. Of Lewes, 416 F.2d 290, 300 (3d Cir. 1969)). 8 The District contends that the proposed amendment will cause undue prejudice as it will 9 increase the scope and need for discovery, result in additional and protracted litigation expenses, 10 and will complicate and delay resolution of the administrative appeal, which is the subject matter 11 of this lawsuit. Such delay will also prevent the District from providing needed special education 12 services to Student as he is presently 20 years old and cannot receive special education services 13 after the end of the school year in which he turns 21. 20 U.S.C. § 1412(a)(1)(A). Dkt. 23, p. 5. 14 The ALJ’s order authorizes the District to conduct its proposed initial evaluation to

15 determine Student’s eligibility for special education services, a necessary step to provide Student 16 with special education. Dkt. 11, Appendix A at p. 8. Student previously received special 17 education during the 2018-19 school year until Parent revoked consent for his receipt of those 18 services. Dkt. 11, Appendix A at p. 2-3. Until Parent’s appeal of the administrative ruling is 19 resolved, the District cannot proceed with an initial special education evaluation of Student. 20 Additionally, Student is twenty years old and will no longer be eligible to receive special 21 education under the IDEA after the end of the 2020-2021 school year. Dkt. 23, p. 3. 22 Parent previously urged this Court to remand her case to state court for a swift decision 23 so that Student can return to school. Dkt. 7 at 4. Parent now responds that the District’s concerns 1 of delay are moot because the District cannot provide the Student any services that he does not 2 already have at home due to COVID-19 concerns, and that Student is presently homeschooling 3 to complete his remaining Washington State high school graduation requirements. Dkt. 25. 4 However, Parent does not address the District’s concerns about additional litigation expense and 5 undue complication of this matter. Parent essentially argues that the proposed claims, even if

6 brought in a separate action, would be subject to consolidation with this case because the claims 7 involve the same defendant and arise from the same set of facts. Dkt. 25. Parent is also involved 8 in a second administrative appeal that is pending in the Office of Administrative Hearings 9 (apparently dealing with the Student’s prior IEPs). Dkt. 20. Although a decision in that appeal 10 has not yet been issued, Plaintiff states she will file suit and move to consolidate that case also. 11 Dkt. 25, p. 3. 12 At the outset, the Court notes there is no motion to consolidate pending. Although any 13 separately filed lawsuit may ultimately be referred to the undersigned as a related case, such 14 referral and/or any properly filed motion to consolidate must be considered at the time of filing.

15 See Fed. R. Civ. P. 42 and LCR 42(a) and (b) (requiring parties to meet and confer).

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C.M.E. v. Shoreline School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cme-v-shoreline-school-district-wawd-2020.