E.E. v. Norris School District

District Court, E.D. California·Decided August 28, 2023·No. 1:20-cv-01291·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 E.E. by and through his guardian ad litem, Case No. 1:20-cv-01291-ADA-CDB LAURA HUTCHINSON-ESCOBEDO, et 12 al., FINDINGS AND RECOMMEMDATION TO APPROVE PLAINTIFFS’ MOTION 13 Plaintiffs/Counter- FOR APPROVAL OF MINOR’S Defendants, COMPROMISE 14 v. (Doc. 98) 15 NORRIS SCHOOL DISTRICT, 16 Defendant/ Counter- 17 Plaintiff. 18 19 20 Pending before the Court is the motion of Plaintiff E.E, a minor, by and through his parent 21 and guardian ad litem, Laura Hutchinson-Escobedo, for approval of the parties’ proposed 22 settlement of E.E.’s damage claims pursuant to Federal Rule of Civil Procedure 17(c) and Local 23 Rule 202(b). The proposed settlement will resolve E.E.’s claims under the Americans with 24 Disabilities Act (“ADA”) and Section 504 of the Rehabilitation Act of 1973 (“Section 504”). 25 (Doc. 98-1 p. 1). The Court recommends that the minor’s compromise be approved as the 26 settlement agreement is fair, reasonable, and in the best interests of the child. 27 / / / 1 I. Factual and Procedural History1 2 E.E. is a minor who has been diagnosed with autism spectrum disorder. (Doc. 90 p. 1). As 3 a result of his autism, E.E. has significant challenges with communication, social skills, sensory 4 processing, fine motor skills, executive functions, and behavior. (Doc. 25; First Amended 5 Complaint (“FAC”) ⁋ 7). He currently is 10 years old. (Doc. 98-1 p. 1). Plaintiffs Laura 6 Hutchinson-Escobedo and Christopher Escobedo are E.E.’s parents (“Parents”). E.E. is eligible 7 to receive special education and related services from Defendant under the Individuals with 8 Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq. (Id.) 9 E.E. started attending kindergarten at Norris Elementary in August 2018. (Doc. 90 p.1). 10 E.E. was under an Individualized Education Plan (“Old IEP”) which allowed him to take part in a 11 general education classroom for 98% of the time with 2% of his time spent on speech and 12 language services. The Old IEP was implemented on November 27, 2018, but was scheduled to 13 end on November 27, 2019. (Id.) 14 The parties met repeatedly and discussed the implementation of a new IEP. Defendant 15 offered a new IEP which sought to move E.E. to Bimat Elementary and place him in a special day 16 class with a trained behavior aide for the most part and cutting down his general education class 17 time to 32%. (Doc. 90 p. 2). Parents did not agree with this new IEP and filed a due process 18 complaint on January 14, 2020. (Id.) E.E.’s parents alleged that Defendant denied E.E. a free 19 appropriate public education (“FAPE”) under the IDEA. Defendant filed its own due process 20 complaint against the Parents, and their complaints were consolidated. (Id.) 21 On September 2, 2020, the assigned administrative law judge (“ALJ”) issued a ruling that 22 was partially favorable to E.E.’s parents and partially favorable to Defendant. The ALJ found 23 that Defendant denied E.E. a FAPE between November 27, 2018, and January 22, 2020, due to 24 inadequate implementation of the Old IEP as written. (Doc. 90 p. 2). However, the ALJ approved 25 the new IEP proposed by Defendant and over the Parents’ objections. 26 1 The facts set forth herein largely are derived from the Court’s earlier order on the parties’ 27 motions for summary judgement (Doc. 90) and from the Plaintiffs’ instant motion for approval of minor’s compromise, which Defendant did not oppose. See Local Rule 230(c) (“A failure to file 1 Plaintiffs initiated this action with the filing of a complaint on September 10, 2020. (Doc. 2 1). Under the operative first amended complaint (“FAC”) Plaintiffs raised four causes of action. 3 First Plaintiffs sought judicial review of the ALJs decision that Defendant may implement the 4 new IEP over the Parents’ objections. (Doc. 25 ⁋⁋ 39-45). Second, Plaintiffs sought an award of 5 reasonable attorney’s fees and costs under 20 U.S.C. § 1415(i)(3)(B) as the prevailing party in the 6 underlying administrative proceeding. (Id. at ⁋⁋ 64-67). 7 Third, Plaintiffs alleged that Defendant violated Section 504 of the Rehabilitation Act. (29 8 U.S.C. § 794). For this claim, Plaintiffs allege that Defendant: (1) denied E.E. the services and 9 reasonable accommodations needed to enjoy meaningful access to the benefits of a public 10 education; (2) failed to take prompt and effective action to prevent disability-based harassment 11 and bullying on school grounds; and (3) failed to provide E.E. with a “free appropriate public 12 education” in violation of Section 504’s implementing regulation. 34 C.F.R. § 104.33(b)(1). (Id. 13 at ⁋⁋ 46-57). Fourth, Plaintiffs allege that Defendant discriminated against E.E. in violation of 14 the ADA. 42 U.S.C. § 12101 et seq. (Id. ⁋⁋ 58-63). 15 Defendant filed two counterclaims against Plaintiffs. (Doc. 23). The first counterclaim 16 was a cross appeal of the ALJs decision that Defendant denied E.E. a FAPE from March 18, 17 2020, through May 7, 2020, by materially failing to implement his IEP during a COVID-19 18 school closure. (Id. at ⁋⁋144-48). Defendant’s second counterclaim sought an award of 19 attorney’s fees and costs against the Parents based on an allegation that their due process claims 20 were brought for improper purposes. (Id. at ⁋⁋ 149-54). Defendant’s second counterclaim was 21 dismissed by the Court on September 22, 2021. (Doc. 54 pp. 4-6). 22 On April 27, 2023, the Court issued an Order which resolved the cross-appeals in favor of 23 Plaintiffs. (Doc. 90). Following the Court’s order, the parties began discussing settlement and 24 finalized a settlement agreement on August 11, 2023. (Doc. 98-1 p. 4). 25 II. Terms of the Proposed Settlement 26 Under the terms of the proposed settlement, E.E. will receive $17,000 in exchange for the 27 release of claims through the date of the agreement. The settlement also provides for the payment 1 III. Settlement Approval Standards 2 No settlement or compromise of “a claim or against a minor or incompetent person” is 3 effective unless it is approved by the Court. Local Rule 202(b). The purpose of requiring the 4 court’s approval is to provide an additional level of oversight to ensure that the child’s interests 5 are protected. K.M. v. Tehachapi School District, Case No. 1:17-cv-01431-LJO-JLT, 2019 WL 6 991048, at *4 (E.D. Cal. Feb. 28, 2019). Under Local Rule 202(b)(2) a party seeking approval of 7 the settlement must disclose: 8 [T]he age and sex of the minor, the nature of the causes of action to be settled or compromised, the facts and circumstances out of which 9 the causes of action arose, including the time, place and persons involved, the manner in which the compromise amount ... was 10 determined, including such additional information as may be required to enable the Court to determine the fairness of the 11 settlement or compromise, and, if a personal injury claim, the nature and extent of the injury with sufficient particularity to inform the 12 Court whether the injury is temporary or permanent. 13 L.R. 202(b)(2). Under Federal Rule of Civil Procedure 17(c), the Court has a responsibility to 14 safeguard the interests of child-litigants. Robidoux v.

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