SPB v. Washoe County School District

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

Opinion

2 UNITED STATES DISTRICT COURT

3 DISTRICT OF NEVADA

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

5 Plaintiffs, ORDER AWARDING v. 6 REIMBURSEMENT WASHOE COUNTY SCHOOL 7 DISTRICT,

8 Defendant.

9 10 Plaintiffs SPB, NH, and JHB sued Defendant Washoe County School 11 District for violations of JHB’s rights under the Individuals with Disabilities 12 Education Act (“IDEA”). The Court previously granted Plaintiffs partial summary 13 judgment, finding that the District violated its child find obligation and denied 14 JHB a free appropriate public education (“FAPE”) under the IDEA. (ECF No. 57.) 15 The Court ordered supplemental briefing on the appropriate remedy for the 16 District’s violation and heard oral argument on that issue on May 7, 2025. (ECF 17 No. 86.) Pending before the Court is Plaintiffs’ motion for reimbursement (ECF 18 No. 80) and several related motions (ECF Nos. 53, 59, 67, 68, 73). 19 For the following reasons, the Court grants in part Plaintiffs’ motion for 20 reimbursement (ECF No. 80) and awards Plaintiffs reimbursement in the sum of 21 $198,833.21 for the District’s FAPE violation. 22 I. DISCUSSION 23 Because the Court’s prior order on liability (ECF No. 57) summarized the 24 facts of this case and because the parties are familiar with those facts, the Court 25 discusses facts below only as relevant to each issue. 26 The Court heard oral argument on the motions addressed in this order on 27 May 7, 2025. Parties first discussed motions related to the issue of whether 28 1 Plaintiffs may seek reimbursement for the costs of Arise, a remedy which they 2 had previously waived. (ECF Nos. 53, 67, 73.) Parties then discussed the 3 supplemental briefing that the Court had requested on the issue of remedies more 4 generally. (ECF No. 80.) The Court addresses each in turn. 5 A. Waiver 6 The Court first addresses the issue of whether Plaintiffs can seek 7 reimbursement for the costs of JHB’s enrollment at the Arise society, a Utah- 8 based transitional program. JHB was enrolled at Arise from October 2021 until 9 her graduation in January 2024. (ECF No. 80 at 1.) 10 Plaintiffs filed their due process complaint against the District in February 11 2021. (AR 898–903.) In October 2021, JHB enrolled at Arise. (AR 2607.) One 12 month later, in November 2021, an administrative hearing was held. (AR 1–828.) 13 In March 2022, the Hearing Officer (“HO”) found that the District was not liable. 14 (AR 1283–1308.) In May 2022, the State Review Officer (“SRO”) reversed that 15 decision, finding that the District violated its child find duty and ordering 16 compensatory education as a remedy. (AR 3488–91.) Plaintiffs filed the complaint 17 in this case in July 2022, appealing the SRO’s decision and seeking 18 reimbursement rather than compensatory education. (ECF No. 1 at 12.) 19 Throughout the course of litigation before this Court, Plaintiffs made clear that 20 they were not seeking reimbursement for the costs of Arise. (ECF Nos. 13, 31, 21 32.) 22 Plaintiffs first sought reimbursement for Arise in July 2024 in an “errata,” 23 two years after filing their complaint and eight months after filing motions for 24 judgment in this case (ECF No. 47). They refiled that motion as a request for leave 25 to file a motion to reinstate waived damages in September 2024 (ECF No. 53). 26 After the Court’s prior order, which deferred ruling on this issue (ECF No. 57), 27 Plaintiffs filed a motion requesting leave to supplement the administrative record 28 1 with documents related to Arise (ECF No. 67). Defendants moved to strike that 2 motion, arguing that the motion was an improper third attempt to address an 3 issue which the Court previously deferred ruling on (ECF No. 73). 4 1. Plaintiffs Waived the Remedy of Reimbursement for Arise 5 Parties agree that Plaintiffs waived the issue of reimbursement for Arise, 6 but dispute whether any exception to that waiver applies. Plaintiffs argue that 7 the Court should exercise its discretion to reach an otherwise waived issue 8 because their claim for reimbursement for Arise is meritorious under the IDEA 9 and because an exception to waiver applies. (ECF No. 53.) The District argues 10 that leave should be denied as futile because no exception to overcome the waiver 11 applies and that Plaintiffs should be judicially estopped from adding Arise as a 12 new remedy at this point in the litigation. (ECF No. 55.) Because the Court finds 13 that no exception to waiver applies, it need not reach the issue of judicial 14 estoppel. 15 “A waiver occurs when ‘a party intentionally relinquishes a right’ or ‘when 16 that party’s acts are so inconsistent with an intent to enforce the right as to 17 induce a reasonable belief that such right has been relinquished.’” Salyers v. 18 Metropolitan Life Insurance Company, 871 F.3d 934, 938 (9th Cir. 2017) (citing 19 Intel Corp. v. Hartford Accident & Indem. Co., 952 F.2d 1551, 1559 (9th Cir. 1991). 20 “[A]n appellant’s failure to argue an issue in the opening brief, much less on 21 appeal more generally, waives that issue,” with certain exceptions. Freedom From 22 Religion Found., Inc. v. Chino Valley Unified Sch. Dist. Bd. of Educ., 896 F.3d 1132, 23 1152 (9th Cir. 2018). 24 Here, Plaintiffs repeatedly stated that they would not be seeking 25 reimbursement for Arise throughout the course of litigation before this Court. In 26 October 2022, Plaintiffs stated in their joint case management report that they 27 did not anticipate discovery would be needed and that “[t]he relevant evidence is 28 1 contained in the administrative record.” (ECF No. 13 at 6.) In September 2023, 2 Plaintiffs filed two motions for judgment, one focused on liability and the other 3 on remedies. (ECF Nos. 31, 32.) In the first, they requested reimbursement for 4 several placements (as detailed below), but not for Arise. (ECF No. 31.) In the 5 second, they expressly stated that they were “not pursuing reimbursement for 6 Arise.” (ECF No. 32 at 28.) These statements constitute a clear waiver. 7 2. Plaintiffs Failed to Demonstrate Good Cause to Supplement and no Exception to Waiver Applies 8 “A party may not file supplemental pleadings, briefs, authorities, or 9 evidence without leave of court granted for good cause.” LR 7-2(g). In their motion, 10 Plaintiffs argue that good cause exists because an exception to the waiver should 11 apply. (ECF No. 53 at 7–8.) They do not address their eight-month delay in 12 bringing this request or argue that they were reasonably diligent in bringing this 13 motion. (See id.) 14 Plaintiffs point to In re Mercury Interactive Corp. Securities Litigation for the 15 Ninth Circuit’s “general rule” against entertaining arguments on appeal that were 16 not presented or developed before the lower court. 618 F.3d 988, 992 (9th Cir. 17 2010). In that case, the Ninth Circuit explained that courts may exercise 18 discretion to reach waived issues only in three circumstances: (1) “‘in the 19 exceptional case in which review is necessary to prevent a miscarriage of justice 20 or to preserve the integrity of the judicial process,’” (2) “‘when a new issue arises 21 while appeal is pending because of a change in the law,’” and (3) “when the issue 22 presented is purely one of law and either does not depend on the factual record 23 developed below, or the pertinent record has been fully developed.” Id. (citing 24 Bolker v. Comm’r,

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

SPB v. Washoe County School District (SPB v. Washoe County School District) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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