Cynthia K. v. Portsmouth School Department

2020 DNH 092
CourtDistrict Court, D. New Hampshire
DecidedJune 2, 2020
Docket19-cv-1129-JD
StatusPublished
Cited by1 cases

This text of 2020 DNH 092 (Cynthia K. v. Portsmouth School Department) 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
Cynthia K. v. Portsmouth School Department, 2020 DNH 092 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Cynthia K.

v. Civil No. 19-cv-1129-JD Opinion No. 2020 DNH 092 Portsmouth School Department

O R D E R

This is a case brought under the Individuals with

Disabilities in Education Act (“IDEA”), 20 U.S.C. § 1400, et

seq. The plaintiff, Cynthia K., challenges the decision of a

New Hampshire Department of Education hearing officer that

Portsmouth School Department is not required to pay for an

independent educational evaluation (“IEE”) of her son, S.K.

Portsmouth School Department (“Department”) asks the court to

affirm the hearing officer’s decision.

Statutory Framework

The purpose of the IDEA includes “ensur[ing] that all

children with disabilities have available to them a free

appropriate public education [“FAPE”]” and “ensur[ing] that the

rights of children with disabilities and parents of such

children are protected.” 20 U.S.C. § 1400(d)(1)(A) & (B); J.S.

v. Westerly Sch. Dist., 910 F.3d 4, 7 (1st Cir. 2018). Under

the IDEA, school districts are required to find and evaluate children with disabilities who live in the school district and

who may require special education or related services. 20

U.S.C. § 1412(a)(3)(A). New Hampshire receives federal funds in

order to provide FAPE for its children, under the IDEA, and has

enacted policies and procedures for the required educational

services. Manchester Sch. Dist. v. Crisman, 306 F.3d 1, 10 (1st

Cir. 2002).

Before special education and related services are provided,

however, a state or local educational agency must conduct “a

full and individual initial evaluation.” 20 U.S.C. §

1414(a)(1)(A). Once an initial evaluation is done, if the

parent disagrees, the parent may request that the school

district provide an IEE at public expense. 34 C.F.R. §

300.502(b)(1). In response, the school district may either pay

for an IEE or file a due process complaint to request a due

process hearing to show that the initial evaluation is

appropriate.1 § 300.502(b)(2). At a hearing under §

300.502(b)(2), the school district bears the burden to show that

1 A parent may file a due process complaint to challenge “the identification, evaluation or educational placement of a child with a disability, or the provision of FAPE to the child.” 34 C.F.R. § 300.507; Collette v. District of Columbia, 2019 WL 3502927, at *2 (D.D.C. Aug. 1, 2019). Cynthia K. did not file a due process complaint to challenge the eligibility determination, and instead requested an IEE.

2 the initial evaluation is appropriate. Id. A party who

disagrees with the hearing officer’s decision may bring a civil

action in this court. 20 U.S.C. § 1415(i)(2).

Standard of Review

In an IDEA case seeking review of the decision of a hearing

officer, the court “shall receive the record of the

administrative proceedings; . . . shall hear additional evidence

at the request of a party; and basing its decision on the

preponderance of the evidence, shall grant such relief as the

court determines is appropriate.” 20 U.S.C. § 1415(i)(2)(C).

Despite that seemingly straightforward statutory provision, in

reviewing the administrative record and other evidence, the

court is instructed to apply a standard of “involved oversight,

a standard which falls somewhere between the highly deferential

clear error standard and the non-deferential de novo standard.”

South Kingston Sch. Comm. v. Joanna S., 773 F.3d 344, 349 (1st

Cir. 2014). To implement involved oversight, the court makes an

independent ruling, by a preponderance of the evidence, from the

administrative record and any other evidence introduced, but

that independent review must be “tempered by the requirement

that the court give due weight to the hearing officer’s

findings.” Johnson v. Boston Pub. Schs., 906 F.3d 182, 191 (1st

3 Cir. 2018). The party seeking review bears the burden of

showing that the hearing officer’s decision is wrong. Del

Rosario v. Nashoba Reg’l School District, 419 F. Supp. 3d 210,

220 (D. Mass. 2019).

Background

A. Factual Background2

In the fall of 2017, S.K. enrolled at New Franklin School

in the Portsmouth School Department as a kindergarten student.

After he enrolled, the Department received S.K.’s early

intervention records, records from when S.K. was referred for

special education at the age of three, medical treatment

records, and other treatment and evaluation records. Cynthia K.

made a written referral of S.K. for special education, but the

Department decided not to evaluate him at that time. The

Department did develop a “Section 504 Plan” for S.K. to address

feeding issues and impulsivity.3

2The background information is summarized from the parties’ joint statement of material facts. See doc. no. 10. Each party also filed a list of disputed facts, which have been reviewed and are referenced as necessary.

3Section 504 presumably refers to Section 504 of the Rehabilitation Act of 1973 that requires non-discriminatory access to public institutions, including schools. Doucette v. Georgetown Pub. Schs., 936 F.3d 16, 24-25 (1st Cir. 2019).

4 During kindergarten, S.K.’s behavior caused his teacher to

request school intervention services. The Department’s Section

504 Team developed a Section 504 Plan to provide accommodations

for S.K.’s “dysphagia and h [sic] impulsivity.” Doc. no. 10 at

3. In December of 2017, S.K.’s kindergarten teacher requested

school intervention services because of S.K.’s frequent

disruptive and noncompliant behavior. The school developed an

action plan to address those issues and added counseling and a

behavior plan to S.K.’s Section 504 Plan. In April of 2018, the

Section 504 team added accommodations for S.K.’s impulsivity and

physical therapy to his Section 504 Plan.

S.K.’s behavior issues continued into first grade. The

special education coordinator at New Franklin School referred

S.K. for a “Functional Behavior Assessment” because of his

noncompliant and unsafe behavior. The assessment was done by

Dr. Jodi Deming between October 16 and November 6, 2018, and

resulted in a report with a recommended positive behavior plan.

The short-term objective was to reduce S.K’s daily noncompliance

level by 75% and his weekly unsafe behavior level by 90%. The

plan included programming to teach S.K. about ways to cope, to

communicate, and to change his behavior.

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