E.C.D v. San Diego Unified School District

CourtDistrict Court, S.D. California
DecidedJanuary 24, 2025
Docket3:23-cv-00303
StatusUnknown

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

Bluebook
E.C.D v. San Diego Unified School District, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 SOUTHERN DISTRICT OF CALIFORNIA 11 12 E.C.D. By and Through His Guardian Ad Case No.: 23-cv-303-RSH-MSB Litem, FARAH CHERY, 13 ORDER AFFIRMING DECISION OF Plaintiff, 14 ADMINISTRATIVE LAW JUDGE v. 15 [ECF No. 35] SAN DIEGO UNIFIED SCHOOL 16 DISTRICT, 17 Defendant. 18 19 20 Plaintiff E.C.D., by and through his guardian ad litem, Farah Chery, appeals a 21 November 18, 2022 decision of an administrative law judge (the “ALJ’s Decision”) under 22 the Individuals with Disabilities Education Act (the “IDEA”), 20 U.S.C. § 1415(i)(2)(A). 23 The ALJ’s Decision determined that defendant San Diego Unified School District 24 (the “District”) provided Plaintiff with an individualized education program (“IEP”) that 25 offered a free appropriate public education (“FAPE”) in the least restrictive environment. 26 27 1 AR 1059–60.1 In this appeal, Plaintiff alleges several errors by the ALJ; the District asks 2 this Court to affirm the ALJ’s Decision. 3 The Parties have fully briefed their positions, and the Court finds the matter suitable 4 for decision without oral argument pursuant to Civil Local Rule 7.1(d)(1).2 After review of 5 the record and the Parties’ written submissions, the Court affirms the ALJ’s Decision and 6 enters judgment in favor of the District. 7 I. BACKGROUND 8 A. Statutory Background 9 Congress enacted the IDEA to ensure “all children with disabilities have available 10 to them a free appropriate public education”—also called a FAPE—“that emphasizes 11 special education and related services designed to meet their unique needs.” 20 U.S.C. § 12 1400(d)(1)(A). The IDEA imposes a “least restrictive environment” requirement, under 13 which states must ensure that “children with disabilities . . . are educated with children who 14 are not disabled” and that “removal of children with disabilities from the regular 15 educational environment occurs only when the nature or severity of the disability of a child 16 is such that education in regular classes with the use of supplementary aids and services 17 cannot be achieved satisfactorily.” 20 U.S.C. § 1412(a)(5)(A). 18 To this end, the IDEA requires that students “receive a FAPE through the 19 development of an individualized education program.” McIntyre v. Eugene Sch. Dist. 4J, 20 976 F.3d 902, 910 (9th Cir. 2020). The IEP is “the centerpiece of the statute’s education 21 delivery system for disabled children.” Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. 22 Dist. RE-1, 580 U.S. 386, 391 (2017) (citation omitted). Every IEP must include statements 23 24 25 1 All citations to the Administrative Record (“AR”) refer to the page numbers in the 26 top right-hand corner of the AR, filed as ECF No. 46. 2 The IDEA provides the court “shall hear additional evidence at the request of a 27 1 about “the child’s present levels of academic achievement,” “measurable annual goals,” 2 and an explanation of “the extent, if any, to which the child will not participate with 3 nondisabled children in the regular class.” 20 U.S.C. § 1414(d)(1)(A). 4 An “IEP Team” composed of parents, teachers, and experts develops the IEP. 20 5 U.S.C. § 1414(d)(1)(B). When parents and educators disagree about a child’s IEP, the 6 IDEA provides for informal dispute resolution procedures and mediation. Id. §§ 1415(e), 7 (f)(1)(B)(i). If these measures fail, the aggrieved party is entitled to a “due process hearing” 8 before the State or local educational agency. 20 U.S.C. § 1415(f). 9 Under California Education Code § 56346(f), when a parent does not consent to a 10 component of a district’s proposed IEP, and the district determines this component is 11 necessary to provide a FAPE, “a due process hearing shall be initiated.”3 This provision 12 “compels a school district to initiate a due process hearing when the school district and the 13 parents reach an impasse.” I.R. ex rel. E.N. v. Los Angeles Unified Sch. Dist., 805 F.3d 14 1164, 1169 (9th Cir. 2015). “[A]t the conclusion of the administrative process, the losing 15 party may seek redress in state or federal court.” Endrew, 580 U.S. at 392. 16 B. Factual Background 17 E.C.D. is an eight-year-old student who qualifies for an IEP under the handicapping 18 conditions of Hard of Hearing and Speech and Language Impairment. ECF No. 35 at 1. 19 E.C.D. was found eligible for special education in December of 2018. ECF No. 35 at 1. At 20 the time, the Parties engaged in IEP discussions for the first time. ECF No. 43 at 3. After 21 numerous IEP meetings and disagreement between the Parties regarding the proper IEP, 22 on February 9, 2021, the Parties entered into a settlement agreement. Id. As part of the 23 24 25 3 A party will “file for due process” to request a due process hearing. At this hearing, 26 “all parties may be accompanied by counsel, and may present evidence and confront, cross- examine, and compel the attendance of witnesses.” Schaffer ex rel. Schaffer v. Weast, 546 27 1 settlement, the Parties agreed to meet to create a new IEP for E.C.D. in December 2021. 2 ECF No. 35 at 2. Between November 20, 2021 and December 16, 2021, the District 3 completed assessments of E.C.D. in preparation for the new IEP, including a psychological 4 evaluation by District psychologist Dr. Renate Ward. AR 157, 726. The Parties met for an 5 IEP meeting on December 16, 2021, but did not complete the IEP and scheduled a follow- 6 up meeting for January 12, 2022. 7 1. Development of January 12, 2022 IEP 8 On January 12, 2022, the IEP team reconvened to discuss E.C.D.’s IEP. AR 3, 158. 9 The next day, on January 13, 2022, the District sent E.C.D.’s parents an email with the 10 proposed IEP from the meeting the day before (“January 2022 IEP”). AR 784. Among 11 other services, the offer included five hours per week of specialized DHH services, pushed 12 into the regular classroom to support E.C.D.’s reading, writing, math and self-advocacy. 13 AR 234. In response to E.C.D.’s parents’ request for full-time DHH support for E.C.D., 14 the Team Action notes expressed concern that “too much adult support in the classroom 15 could have harmful effects” by creating “dependence on adults, less opportunities for 16 interactions between [E.C.D.] and his peers, and hinder[ing] progress.” Id. As to the 17 location for the January 2022 IEP’s implementation, the document included references to 18 both Florence Elementary School (“Florence”) and Lafayette Elementary School 19 (“Lafayette”) throughout. AR 789. E.C.D.’s parents did not consent to the January 2022 20 IEP and requested an amended IEP with, among other services, full-time DHH support and 21 placement at E.C.D.’s home school, Florence. Id. 22 2. Development of March 25, 2022 IEP 23 On March 16, 2022, the Parties convened for another IEP meeting to discuss 24 potential changes. AR 159. Following the meeting, on March 25, 2022, the District sent a 25 prior written notice (“PWN”) to E.C.D.’s parents with the amended IEP attached (“March 26 2022 IEP”). AR 159, 881. The PWN noted that at the January IEP meeting, the District 27 offered a placement “to be implemented at Lafayette.” Id.

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Bluebook (online)
E.C.D v. San Diego Unified School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ecd-v-san-diego-unified-school-district-casd-2025.