Mrs. J. v. Strafford School

2004 DNH 100
CourtDistrict Court, D. New Hampshire
DecidedJune 28, 2004
DocketCV-03-228-SM
StatusPublished

This text of 2004 DNH 100 (Mrs. J. v. Strafford School) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mrs. J. v. Strafford School, 2004 DNH 100 (D.N.H. 2004).

Opinion

Mrs. J. v . Strafford School CV-03-228-SM 06/28/04 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Mrs. J., Plaintiff

v. Civil N o . 03-228-SM Opinion N o . 2004 DNH 100 Strafford School District, Defendant

O R D E R

Pursuant to the Individuals with Disabilities Education Act

(“IDEA”), 20 U.S.C. §§ 1400 et seq., Mrs. J., mother of

Christopher J., appeals an educational hearing officer’s decision

which was, at least in part, in favor of the local school

district. See 20 U.S.C. § 1415(i)(2). She claims that the

hearing officer “erred by failing to order extended school day

programming [for Christopher] for approximately 11 hours per day,

five days per week.” Plaintiff’s Stipulation Regarding Issues

Plaintiff Plans to Raise on Appeal (document n o . 31) at para. 1 .

She also seeks a judicial declaration that she is the “prevailing

party” and, therefore, entitled to an award of attorney’s fees

and costs. In its counterclaim, the School District challenges the hearing officer’s determination that Christopher is entitled

to direct, one-on-one occupational therapy.

The parties have filed a “certificate of completion,” as

well as their respective decision memoranda. See Local Rule

9.3(b) and ( e ) . Neither party requested a hearing to present

oral argument or additional evidence. The parties have, however,

agreed to postpone any ruling on plaintiff’s request for

attorney’s fees, pending resolution of their substantive

challenges to the hearing officer’s decision. See Stipulation to

Bifurcate the Issues (document n o . 1 8 ) .

Background

The administrative record in this case consists of eight

bound volumes containing approximately 4,400 pages (document nos.

8 and 1 4 ) . And, under Local Rule 9.3(d), the parties have filed

a statement of stipulated facts (document n o . 2 8 ) . The facts

relevant to the disposition of this matter are discussed as

appropriate, and are drawn from the stipulation and

administrative record.

2 Standard of Review

Congress enacted the Individuals with Disabilities Education

Act “to ensure that all children with disabilities have available

to them a free appropriate public education that emphasizes

special education and related services designed to meet their

unique needs and prepare them for employment and independent

living.” 20 U.S.C. § 1400(d)(1)(A). Under the scheme

established by the IDEA, and in return for federal funding, state

educational agencies establish procedures to identify and

evaluate disabled students in need of special education services.

See 20 U.S.C. § 1412. For each identified child, a team

comprised of the child’s parents, teachers, and a representative

of the educational agency develops an individualized education

plan (“IEP”) for the child.

An IEP consists of “a written statement for each child with

a disability that is developed, reviewed, and revised in

accordance with section 1414(d) of [the IDEA].” 20 U.S.C. §

1401(11). It must be “reasonably calculated to enable the child

to receive educational benefits,” Bd. of Educ. v . Rowley, 458

U.S. 176, 207 (1982), and “custom tailored to address the

3 [disabled] child’s ‘unique needs,’” Lenn v . Portland Sch. Comm.,

998 F.2d 1083, 1086 (1st Cir. 1993) (citing 20 U.S.C. § 1400(c)).

Importantly, however, neither the IDEA nor New Hampshire law

requires the IEP to “maximize” a child’s educational benefits.

See, e.g., Lenn, 998 F.2d at 1086 (holding that, under the IDEA,

“the benefit conferred [by the IEP] need not reach the highest

attainable level or even the level needed to maximize the child’s

potential.”). Instead, the IDEA establishes more modest goals

and imposes upon states and local school districts an obligation

to provide a program that is “sufficient to confer some

educational benefit upon the handicapped child.” Rowley, 458

U.S. at 200.

We therefore conclude that the “basic floor of opportunity” provided by the Act consists of access to specialized instruction and related services which are individually designed to provide educational benefit to the handicapped child.

Id. at 201.

If a parent believes that a proposed IEP will not provide an

appropriate education, or that the procedures established by the

4 IDEA have not been properly followed in developing the IEP, he or

she may request an administrative due process hearing to review

the matter. See 20 U.S.C. § 1415(f). If a parent, or the

affected school district, is dissatisfied with the administrative

hearing officer’s ruling, that party may seek judicial review in

either state or federal court. 20 U.S.C. § 1415(i)(2).

A district court’s review of state educational

administrative proceedings has been described as “one of involved

oversight.” Lenn, 998 F.2d at 1087 (citing Roland M . v . Concord

Sch. Comm., 910 F.2d 983, 989 (1st Cir. 1990)). The applicable

standard is an intermediate one under which the district court

must exercise independent judgment, but, at the same time, give

“due weight” to the administrative proceedings.

The required [judicial review] must, at one and the same time, be thorough yet deferential, recognizing the expertise of the administrative agency, considering the agency’s findings carefully and endeavoring to respond to the hearing officer’s resolution of each material issue. Jurists are not trained, practicing educators. Thus, the statutory scheme binds trial courts to give ‘due weight’ to the state agency’s decision in order to prevent judges from imposing their view of preferable educational methods upon the States.

5 Roland M., 910 F.2d at 989 (citations and internal punctuation

omitted). See also T.B. v . Warwick Sch. Comm., 361 F.3d 8 0 , 83-

84 (1st Cir. 2004).

District court review is focused on two questions: (1)

whether the parties complied with the procedural requirements of

the IDEA; and (2) whether the IEP developed through those

procedures was reasonably calculated to enable the disabled child

to receive educational benefits. See, e.g., Rowley, 458 U.S. at

206-07. The burden of proof rests with the party challenging the

administrative decision. See Hampton Sch. Dist. v . Dobrowolski,

976 F.2d 4 8 , 54 (1st Cir. 1992); Roland M., 910 F.2d at 991.

With those principles in mind, the court turns to the

parties’ respective challenges to the hearing officer’s decision,

dated January 2 8 , 2003.

Discussion

I. Non-residential Placement of Christopher.

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