SPB v. Washoe County School District

District Court, D. Nevada·Decided June 6, 2025·No. 3:22-cv-00340·Unknown

Opinion

SPB, NH, and JHB, individuals, Case No. 3:22-cv-00340-ART-CLB

Plaintiffs, ORDER AWARDING v. WASHOE COUNTY SCHOOL

Defendant.

Plaintiffs SPB, NH, and JHB sued Defendant Washoe County School District for violations of JHB’s rights under the Individuals with Disabilities Education Act (“IDEA”). The Court previously granted Plaintiffs partial summary judgment, finding that the District violated its child find obligation and denied JHB a free appropriate public education (“FAPE”) under the IDEA. (ECF No. 57.) The Court ordered supplemental briefing on the appropriate remedy for the District’s violation and heard oral argument on that issue on May 7, 2025. (ECF No. 86.) Pending before the Court is Plaintiffs’ motion for reimbursement (ECF No. 80) and several related motions (ECF Nos. 53, 59, 67, 68, 73). For the following reasons, the Court grants in part Plaintiffs’ motion for reimbursement (ECF No. 80) and awards Plaintiffs reimbursement in the sum of $198,833.21 for the District’s FAPE violation. Because the Court’s prior order on liability (ECF No. 57) summarized the facts of this case and because the parties are familiar with those facts, the Court discusses facts below only as relevant to each issue. The Court heard oral argument on the motions addressed in this order on May 7, 2025. Parties first discussed motions related to the issue of whether Plaintiffs may seek reimbursement for the costs of Arise, a remedy which they had previously waived. (ECF Nos. 53, 67, 73.) Parties then discussed the supplemental briefing that the Court had requested on the issue of remedies more generally. (ECF No. 80.) The Court addresses each in turn. A. Waiver The Court first addresses the issue of whether Plaintiffs can seek reimbursement for the costs of JHB’s enrollment at the Arise society, a Utah- based transitional program. JHB was enrolled at Arise from October 2021 until her graduation in January 2024. (ECF No. 80 at 1.) Plaintiffs filed their due process complaint against the District in February 2021. (AR 898–903.) In October 2021, JHB enrolled at Arise. (AR 2607.) One month later, in November 2021, an administrative hearing was held. (AR 1–828.) In March 2022, the Hearing Officer (“HO”) found that the District was not liable. (AR 1283–1308.) In May 2022, the State Review Officer (“SRO”) reversed that decision, finding that the District violated its child find duty and ordering compensatory education as a remedy. (AR 3488–91.) Plaintiffs filed the complaint in this case in July 2022, appealing the SRO’s decision and seeking reimbursement rather than compensatory education. (ECF No. 1 at 12.) Throughout the course of litigation before this Court, Plaintiffs made clear that they were not seeking reimbursement for the costs of Arise. (ECF Nos. 13, 31, 32.) Plaintiffs first sought reimbursement for Arise in July 2024 in an “errata,” two years after filing their complaint and eight months after filing motions for judgment in this case (ECF No. 47). They refiled that motion as a request for leave to file a motion to reinstate waived damages in September 2024 (ECF No. 53). After the Court’s prior order, which deferred ruling on this issue (ECF No. 57), Plaintiffs filed a motion requesting leave to supplement the administrative record with documents related to Arise (ECF No. 67). Defendants moved to strike that motion, arguing that the motion was an improper third attempt to address an issue which the Court previously deferred ruling on (ECF No. 73). 1. Plaintiffs Waived the Remedy of Reimbursement for Arise Parties agree that Plaintiffs waived the issue of reimbursement for Arise, but dispute whether any exception to that waiver applies. Plaintiffs argue that the Court should exercise its discretion to reach an otherwise waived issue because their claim for reimbursement for Arise is meritorious under the IDEA and because an exception to waiver applies. (ECF No. 53.) The District argues that leave should be denied as futile because no exception to overcome the waiver applies and that Plaintiffs should be judicially estopped from adding Arise as a new remedy at this point in the litigation. (ECF No. 55.) Because the Court finds that no exception to waiver applies, it need not reach the issue of judicial estoppel. “A waiver occurs when ‘a party intentionally relinquishes a right’ or ‘when that party’s acts are so inconsistent with an intent to enforce the right as to induce a reasonable belief that such right has been relinquished.’” Salyers v. Metropolitan Life Insurance Company, 871 F.3d 934, 938 (9th Cir. 2017) (citing Intel Corp. v. Hartford Accident & Indem. Co., 952 F.2d 1551, 1559 (9th Cir. 1991). “[A]n appellant’s failure to argue an issue in the opening brief, much less on appeal more generally, waives that issue,” with certain exceptions. Freedom From Religion Found., Inc. v. Chino Valley Unified Sch. Dist. Bd. of Educ., 896 F.3d 1132, 1152 (9th Cir. 2018). Here, Plaintiffs repeatedly stated that they would not be seeking reimbursement for Arise throughout the course of litigation before this Court. In October 2022, Plaintiffs stated in their joint case management report that they did not anticipate discovery would be needed and that “[t]he relevant evidence is contained in the administrative record.” (ECF No. 13 at 6.) In September 2023, Plaintiffs filed two motions for judgment, one focused on liability and the other on remedies. (ECF Nos. 31, 32.) In the first, they requested reimbursement for several placements (as detailed below), but not for Arise. (ECF No. 31.) In the second, they expressly stated that they were “not pursuing reimbursement for Arise.” (ECF No. 32 at 28.) These statements constitute a clear waiver. 2. Plaintiffs Failed to Demonstrate Good Cause to Supplement and no Exception to Waiver Applies “A party may not file supplemental pleadings, briefs, authorities, or evidence without leave of court granted for good cause.” LR 7-2(g). In their motion, Plaintiffs argue that good cause exists because an exception to the waiver should apply. (ECF No. 53 at 7–8.) They do not address their eight-month delay in bringing this request or argue that they were reasonably diligent in bringing this motion. (See id.) Plaintiffs point to In re Mercury Interactive Corp. Securities Litigation for the Ninth Circuit’s “general rule” against entertaining arguments on appeal that were not presented or developed before the lower court. 618 F.3d 988, 992 (9th Cir. 2010). In that case, the Ninth Circuit explained that courts may exercise discretion to reach waived issues only in three circumstances: (1) “‘in the exceptional case in which review is necessary to prevent a miscarriage of justice or to preserve the integrity of the judicial process,’” (2) “‘when a new issue arises while appeal is pending because of a change in the law,’” and (3) “when the issue presented is purely one of law and either does not depend on the factual record developed below, or the pertinent record has been fully developed.” Id. (citing Bolker v. Comm’r, 760 F.2d 1039, 1042 (9th Cir. 1985)). The District argues that In re Mercury is inapplicable because that case involved a waiver on appeal for failure to present the issue to the lower district court, whereas this case involves an express waiver of a remedy in briefing before the reviewing court. (ECF No. 55 at 17.) But even under In re Mercury, Plaintiffs have failed to show that an

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SPB v. Washoe County School District, (D. Nev. 2025).

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