Escondido Union High School District v. Tony Aloy and Ashley Wendel, parents on behalf of C.A., a minor student

CourtDistrict Court, S.D. California
DecidedOctober 22, 2025
Docket3:24-cv-01653
StatusUnknown

This text of Escondido Union High School District v. Tony Aloy and Ashley Wendel, parents on behalf of C.A., a minor student (Escondido Union High School District v. Tony Aloy and Ashley Wendel, parents on behalf of C.A., a minor student) 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
Escondido Union High School District v. Tony Aloy and Ashley Wendel, parents on behalf of C.A., a minor student, (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 ESCONDIDO UNION HIGH SCHOOL Case No.: 24-cv-1653-RSH-JLB DISTRICT, 13 ORDER REMANDING DECISION OF Plaintiff, 14 ADMINISTRATIVE LAW JUDGE v. 15 [ECF No. 25] TONY ALOY and ASHLEY WENDEL, 16 parents on behalf of C.A., a minor student, 17 Defendant. 18 19 20 Plaintiff Escondido Union High School District (the “District”) brings this action 21 under the Individuals with Disabilities Education Act (the “IDEA”), 20 U.S.C. § 22 1415(i)(2)(A). The District appeals a June 18, 2024 final administrative decision (the 23 “ALJ’s Decision”) that held that the District had denied C.A., a minor student, a free 24 appropriate public education (“FAPE”). Administrative Record (“AR”) 1512–13.1 25 26 1 All citations to the AR refer to the page numbers in the bottom right-hand corner of 27 1 In the instant action, the District alleges several errors by the ALJ; Defendants Tony 2 Aloy and Ashley Wendel, the parents of C.A. (“Parents”),2 request that the Court affirm 3 the ALJ’s Decision. Pursuant to Local Civil Rule 7.1(d)(1), the Court finds the motion 4 presented appropriate for resolution without oral argument.3 For the reasons below, the 5 Court VACATES the ALJ’s decision and REMANDS this action for further proceedings 6 consistent with this Order. 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 individualized education program (“IEP”) is “the 21 centerpiece of the statute’s education delivery system for disabled children.” Endrew F. ex 22 rel. Joseph F. v. Douglas Cnty. Sch. Dist. RE-1, 580 U.S. 386, 391 (2017) (citation 23 24 2 C.A’s mother, Defendant Ms. Wendel, is referred to as “Parent” throughout this 25 Order. 26 3 The IDEA provides the court “shall hear additional evidence at the request of a party,” see 20 U.S.C. § 1415(e)(2), but here neither party has requested an evidentiary 27 1 omitted). Every IEP must include statements about “the child’s present levels of academic 2 achievement,” “measurable annual goals,” and an explanation of “the extent, if any, to 3 which the child will not participate with nondisabled children in the regular class . . . .” 20 4 U.S.C. § 1414(d)(1)(A). 5 An “IEP Team” composed of parents, teachers, educational agency representatives, 6 and experts develops the IEP. 20 U.S.C. § 1414(d)(1)(B). When parents and educators 7 disagree about a child’s IEP, the IDEA provides for informal dispute resolution procedures 8 and mediation. Id. §§ 1415(e), (f)(1)(B)(i). If these measures fail, the aggrieved party is 9 entitled to a “due process hearing” before the State or local educational agency. 20 U.S.C. 10 § 1415(f). 11 Under 34 C.F.R. § 300.502(b)(2) and California Education Code § 56327(c), a 12 parent has the right to request an independent educational evaluation (“IEE”) at public 13 expense if the parent disagrees with an evaluation obtained by the district. If a district 14 denies a parent’s request for an IEE, the district must file a due process complaint to request 15 a hearing on the appropriateness of its evaluation.4 34 C.F.R. § 300.502(b)(2); Cal. Educ. 16 Code § 56327(c). “[A]t the conclusion of the administrative process, the losing party may 17 seek redress in state or federal court.” Endrew, 580 U.S. at 392. 18 B. Factual Background 19 At the time of the hearing before the ALJ in April 2024, C.A. was sixteen years old 20 and qualified for special education and related services under the IDEA. ECF Nos. 25 at 2; 21 28 at 1. C.A. had attended the Winston School (“Winston”), a nonpublic school in San 22 Diego, CA, since April 2022. AR 1472. 23 24 25 4 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 1. Settlement Agreement and Placement at Private School 2 In November 2022, Parents and the District executed a settlement agreement related 3 to C.A.’s education for the 2022–2023 school year. AR 261. As part of the settlement 4 agreement, the District agreed to fund tuition and related services and provide 5 transportation to and from Winston during the 2022–2023 school year; assess C.A. in all 6 areas of suspected disability; convene an IEP meeting prior to the end of the 2022–2023 7 school year to develop an IEP for the 2023–2024 school year; and fund attorneys’ fees and 8 costs up to a designated amount. Id. Parents agreed to waive all educational claims through 9 the conclusion of the 2022–2023 school year. Id. 10 2. Assessment 11 In March 2023, in accordance with the settlement agreement, the District developed 12 a plan to assess C.A. in various areas. ECF Nos. 1 ¶ 25; 28 at 4. District school psychologist 13 Willow Ray and District speech and language pathologist Melissa McNutt-Eidson 14 conducted C.A.’s assessments. ECF No. 28 at 4. 15 On May 11, 2023, Parent completed a social-emotional questionnaire provided by 16 Ms. Ray. Id. On May 25, 2023, Ms. Ray completed C.A.’s psychoeducational and 17 educationally related mental health services (“ERMHS”) assessment report. ECF No. 28 18 at 4. She administered assessments to evaluate C.A.’s eligibility for special education based 19 on cognitive and processing abilities, academics, autism and adaptive behavior needs, and 20 social-emotional and behavioral needs. ECF No. 25 at 3. Ms. Ray concluded that C.A. met 21 continued eligibility criteria for special education under the category of Other Health 22 Impairment (“OHI”) due to attention-deficit/hyperactivity disorder (“ADHD”) and 23 anxiety, and that C.A. did not meet eligibility criteria for special education under the 24 categories of emotional disturbance, specific learning disability, or autism. ECF No. 1 ¶ 25 37. 26 On April 27, 2023, Ms.

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Escondido Union High School District v. Tony Aloy and Ashley Wendel, parents on behalf of C.A., a minor student, Counsel Stack Legal Research, https://law.counselstack.com/opinion/escondido-union-high-school-district-v-tony-aloy-and-ashley-wendel-casd-2025.