J-D. v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedSeptember 22, 2025
DocketCivil Action No. 2024-0707
StatusPublished

This text of J-D. v. District of Columbia (J-D. v. District of Columbia) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J-D. v. District of Columbia, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

S.J-D., et al.,

Plaintiffs,

v. No. 24-cv-00707 (DLF)

DISTRICT OF COLUMBIA,

Defendant.

MEMORANDUM OPINION

R.J., S.D., and their child, S.J-D., bring this action against the District of Columbia under

the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1400 et seq., challenging the

District of Columbia Public Schools’ (DCPS) failure to provide S.J-D. a free appropriate public

education (FAPE). See Compl., Dkt. 3-2. Before the Court is the plaintiffs’ Motion for Summary

Judgment, Dkt. 9, and the District’s Cross-Motion for Summary Judgment, Dkt. 11. For the

following reasons, the Court will deny the plaintiffs’ motion and grant the District’s motion.

I. BACKGROUND

A. Statutory Framework

Under the IDEA, “every child with a disability in this country is entitled to a ‘free

appropriate public education,’ or FAPE.” Leggett v. District of Columbia, 793 F.3d 59, 62 (D.C.

Cir. 2015) (quoting 20 U.S.C. § 1400(d)(1)(A)). For students with disabilities, public school

officials must “develop a comprehensive strategy, known as an ‘individualized education

program,’ or IEP, tailored to the student’s unique needs.” Id. at 63 (quoting 20 U.S.C.

§ 1414(d)(1)(A)). “To meet its substantive obligation under the IDEA, a school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s

circumstances.” Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. Dist., 580 U.S. 386, 399 (2017).

Among other requirements, an IEP must include “a statement of the special education and

related services and supplementary aids and services . . . to be provided to the child” along with

“an explanation of the extent, if any, to which the child will not participate with nondisabled

children in the regular class.” 20 U.S.C. § 1414(d)(1)(A)(i)(IV)–(V). Special education services

“in general education” are provided in the regular classroom and among non-disabled peers,

whereas special education services “outside general education” are provided apart from the general

student population in a specialized classroom. See Z.B. v. District of Columbia, 888 F.3d 515, 528

(D.C. Cir. 2018).

Under the IDEA, “[t]o the maximum extent appropriate, children with disabilities . . . are

educated with children who are not disabled.” 20 U.S.C. § 1412(a)(5)(A). “[S]pecial classes,

separate schooling, or other removal of children with disabilities from the regular educational

environment occurs only when the nature or severity of the disability of a child is such that

education in regular classes with the use of supplementary aids and services cannot be achieved

satisfactorily.” Id. In other words, students must “be educated in the least restrictive environment

possible,” Leggett, 793 F.3d at 74, such that “they receive education in the regular classroom

whenever possible,” Endrew F., 580 U.S. at 400 (citation modified). Under DCPS policy, a

student’s IEP will provide for “full-time” specialized instruction only when she requires “20 or

more hours of specialized instruction per week outside the general education classroom.” D.C.

Pub. Sch. Off. of Specialized Instruction, Programs & Resources Guide for Staff 4 (2014),

https://dcps.dc.gov/sites/default/files/dc/sites/dcps/publication/attachments/GAGA-2015-R0046-

AttachmentJ9OSI14-15ProgramsandResourcesGuideforStaff.pdf.

2 The IDEA also requires local education agencies to “establish and maintain procedures in

accordance with [the IDEA] to ensure that children with disabilities and their parents are

guaranteed procedural safeguards with respect to the provision of a [FAPE].” 20 U.S.C. § 1415(a).

For example, the IDEA provides parents an opportunity “to participate in meetings with respect to

the identification, evaluation, and educational placement of the child, and the provision of a

[FAPE] to such child.” Id. § 1415(b)(1). As relevant here, schools must give “timely access” to

parents or their designee “for observing a child’s current or proposed special educational program”

upon request. D.C. Code § 38-2571.03(5)(A); see 20 U.S.C. § 1401(9) (“The term [FAPE] means

special education and related services that . . . meet the standards of the State educational

agency.”). School districts must also review and revise a student’s IEP “not less frequently than

annually.” 20 U.S.C. § 1414(d)(4)(A)(i)–(ii).

Parents with either substantive or procedural complaints about a school’s “‘identification,

evaluation, or educational placement’ of their child or to its ‘provision of a [FAPE]’ may request

a due-process hearing.” Davis v. District of Columbia, 244 F. Supp. 3d 27, 32 (D.D.C. 2017)

(quoting 20 U.S.C. § 1415(b)(6)). At this hearing, parents are entitled to have counsel accompany

and advise them, to present evidence, to cross-examine witnesses, and to receive a written decision

from the hearing officer. 20 U.S.C. § 1415(h). Parents may then bring a civil action in state or

federal court for judicial review of the hearing officer’s decision. Id. § 1415(i)(2)(A).

B. Factual Background

S.J-D. is a thirteen-year-old student. See Compl. ¶ 4. She attended Francis Stevens

Elementary School (Francis Stevens), a D.C. public school, from 2015 to 2021—from pre-

kindergarten through the fourth grade. See id. ¶ 10. In September 2018, when S.J-D. was in the

second grade, Francis Stevens developed a plan under Section 504 of the Rehabilitation Act to

3 address her ADHD. Administrative Record (AR) 42, Dkt. 7. In February 2020, when S.J-D. was

in the third grade, DCPS found her eligible for special education and related services as a student

with an Other Health Impairment for ADHD, and it developed an initial IEP for S.J-D. AR 91–

92, 102. One month later, in March 2020, Francis Stevens transitioned to virtual learning because

of the COVID-19 pandemic. See AR 116, 122.

S.J-D.’s initial IEP included goals in math, reading, and written expression. AR 104–08.

To achieve those goals, DCPS prescribed specialized instruction of (1) two hours per week in

reading and one hour per week in math, in general education, and (2) one hour per week in written

expression and two hours per week in math, outside general education in a “small setting.” AR

109–10. By the end of the 2019–20 school year, S.J-D.’s progress reports reflected that, out of

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