E.S. et al. v. Newport-Mesa Unified School District

District Court, C.D. California·Decided July 28, 2026·No. 8:25-cv-00484·Unknown

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA —_ CIVIL MINUTES —- GENERAL Case No. 8:25-cv-00484-FWS-JDE Date: July 28, 2026 Title: E.S. et al. v. Newport-Mesa Unified School District Present: HONORABLE FRED W. SLAUGHTER, UNITED STATES DISTRICT JUDGE Rolls Royce Paschal N/A Deputy Clerk Court Reporter Attorneys Present for Plaintiffs: Attorneys Present for Defendant: Not Present Not Present PROCEEDINGS: MEMORANDUM OF DECISION I. Introduction and Background Plaintiffs E.S. and S.S., on behalf of their minor child, D.S. (together, “Plaintiffs”’), filed this action against Defendant Newport-Mesa Unified School District (the “District”’) appealing the decision of an administrative law judge (“ALJ”) in the Office of Administrative Hearings (“OAH”) regarding whether the District provided D.S. adequate educational services. (See Dkt. 1 (Complaint).) In particular, the District provided D.S. with Individualized Education Plans (“IEPs’’), but D.S.’s parents believed the IEPs were not enough to provide him a free appropriate public education (“FAPE”’) as guaranteed by the Individuals with Disabilities Education Act (“IDEA’’). (See id.) The IDEA offers states federal funding for providing a FAPE “to all children with certain physical or intellectual disabilities.” Capistrano Unified Sch. Dist. v. S.W., 21 F.4th 1125, 1129 (9th Cir. 2021), cert. denied sub nom. S.W. on Behalf of B.W. v. Capistrano Unified Sch. Dist., 143 S. Ct. 98 (2022). A FAPE includes instruction tailored to meet the child’s needs and sufficient supportive services to permit the child to benefit from that instruction. Jd. IEPs, which a team of “school officials, teachers, and parents” assembles and annually, are “the primary vehicle for providing each child with a FAPE.” Jd. (cleaned They describe, among other things, measurable academic goals for the child and the “special education and related services and supplementary aids and services” that will be

CIVIL MINUTES — GENERAL

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES – GENERAL

Case No. 8:25-cv-00484-FWS-JDE Date: July 28, 2026 Title: E.S. et al. v. Newport-Mesa Unified School District provided to help the child meet those academic goals. Id. at 1129–30; 20 U.S.C. §§ 1414(d)(1)(A)(i)(II)–(V).

When parents and school districts have disputes over whether a FAPE has been provided, parents may file an administrative complaint. S.W., 21 F.4th at 1129. Then, after a preliminary meeting of the parties, an impartial hearing officer holds a “due process hearing” regarding whether the child received a FAPE. Id. In this case, “Administrative Law Judge Ashok Pathi heard this matter via videoconference on October 1, 2, 9, 10, 11, 15, and 16, 2024.” (AR at 851.) In a 106-page order issued on December 12, 2024, after the parties submitted closing briefs, ALJ Pathi found that D.S. “did not prevail on any issues” and “denied” “[a]ll of [D.S.’s] requested relief.” (Dkt. 23 (Administrative Record, “AR”) at 956.)

Plaintiffs now appeal. See S.W., 21 F.4th at 1129 (“[A] parent unhappy with the outcome of the administrative process may seek judicial review by filing a civil action in state or federal court.”). Before the court are Plaintiffs’ Principal Brief, (Dkt. 33 (“P. Br.”)), Defendant’s Responsive Brief, (Dkt. 34 (“D. Br.”)), and Plaintiffs’ Reply Brief, (Dkt. 36 (“P. Reply”)). The court held a one-day bench trial on June 23, 2026. (Dkt. 37.) At the court’s request at the bench trial, the parties submitted proposed findings of fact and conclusions of law. (Dkt. 38 (“P. PO”); Dkt. 39 (“D. PO”); Dkt. 40.) Based on the record, as applied to the relevant law, the court now AFFIRMS the ALJ’s decision.

II. Standard of Review

“When a party challenges the outcome of an IDEA due process hearing, the reviewing court receives the administrative record, hears any additional evidence, and, ‘basing its decision on the preponderance of the evidence, shall grant such relief as the court determines is appropriate.’” R.B. ex rel F.B. v. Napa Valley Unified Sch. Dist., 496 F.3d 932, 937 (9th Cir. 2007) (quoting 20 U.S.C. § 1415(i)(2)(B)). This means that judicial review in IDEA cases differs from judicial review of other agency actions in two ways. Ojai Unified Sch. Dist. v. Jackson, 4 F.3d 1467, 1471 (9th Cir. 1993). First, while in judicial review of other agency actions courts generally are confined to the administrative record, courts in IDEA cases may “hear additional evidence at the request of a party.” Id. (quoting 20 U.S.C.A. § 1415(e)(2)). ____________________________________________________________________________ UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

CIVIL MINUTES – GENERAL

Case No. 8:25-cv-00484-FWS-JDE Date: July 28, 2026 Title: E.S. et al. v. Newport-Mesa Unified School District Second, whereas “a highly deferential standard of review” applies to review of other agency actions, courts in IDEA cases base their decisions “on the preponderance of the evidence.” Id. However, courts give “due weight” to the administrative decision and take care not to “substitute their own notions of sound educational policy for those of the school authorities.” Van Duyn ex rel. Van Duyn v. Baker Sch. Dist. 5J, 502 F.3d 811, 817 (9th Cir. 2007) (quoting Bd. of Educ. of Hendrick Hudson Cent. Sch. Dist., Westchester Cty. v. Rowley, 458 U.S. 176, 206 (1982)). They consider administrative “findings carefully,” giving “particular deference” when those findings are “thorough and careful.” R.B., 496 F.3d at 937 (quoting Union Sch. Dist. v. Smith, 15 F.3d 1519, 1524 (9th Cir. 1994)).

III. Discussion

Plaintiffs argue the District denied D.S. a FAPE through (A) procedural errors and (B) substantive errors. The court addresses each in turn.

A. Procedural Errors: IEP Team Attendance

“One of the IDEA’s procedural requirements is the creation of an IEP team to determine a child’s eligibility for IDEA benefits.” R.B., ex rel. F.B.v. Napa Valley Unified Sch. Dist., 496 F.3d 932, 938 (9th Cir. 2007). The statute provides what members an IEP team must have, and also provides that IEP team members must be present at IEP meetings unless their attendance is not necessary or they are excused. See 20 U.S.C. §§ 1414(d)(1)(B)-(C).

In this case, Plaintiffs argue the District committed procedural errors that denied D.S. a FAPE by failing to ensure adequate IEP team meeting attendance. (See P. Br. at 15-17.) In particular, Plaintiffs argue the District “did not ensure the attendance of . . . the school psychologist, the occupational therapist, the adapted physical education teacher, and the administrator” at the March 2022 IEP meeting; the school psychologist at the May 2022 IEP meeting; the school psychologist, occupational therapist, and the Adapted Physical Education teacher at the March 2023 IEP meeting; and the school psychologist, occupational therapist, and an administrator at the May 2024 IEP meeting. (Id.)

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