Uhlenkamp v. District of Columbia

CourtDistrict Court, District of Columbia
DecidedJune 9, 2026
DocketCivil Action No. 2021-2662
StatusPublished

This text of Uhlenkamp v. District of Columbia (Uhlenkamp 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
Uhlenkamp v. District of Columbia, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

BOWEN UHLENKAMP AND SADAF LAKHANI, parents of the minor child A.U.,

Plaintiffs, Case No. 1:21-cv-2662 (TNM) v.

DISTRICT OF COLUMBIA,

Defendant.

MEMORANDUM OPINION

This case is another iteration in a years-long dispute between D.C. Public Schools

(“DCPS” or “the District”) and the parents of one of its former students. The parents seek relief

for DCPS’s alleged failure to provide their child an adequate education as required by the

Individuals with Disabilities Education Act (“IDEA”). The parents’ challenge began half a

decade ago, when they took their claims to an administrative hearing officer, who denied them in

full. That denial prompted the parents to turn here hoping to undo the administrative decision.

After the Court remanded the case to the hearing officer for another look, he again denied their

claim and the dispute has thus returned.

The parents move for summary judgment and once more ask this Court to reverse the

hearing officer’s decision. Magistrate Judge Sharbaugh has issued a thorough Report and

Recommendation (“Report”) proposing that the Court grant in part and deny in part the parents’

motion and the District’s cross-motion. The Report and Plaintiffs’ objections to it are now

before the Court. Because the hearing officer adequately substantiated his conclusions on his

second go at the case for some claims but not others, the Court will adopt the Report in full and

thus grant in part and deny in part both motions. I.

The Court’s first opinion in this case details its factual background at length. See

Uhlenkamp v. District of Columbia, 691 F. Supp. 3d 224, 229 (D.D.C. 2023). Because there is

no need to rehash those facts, the Court provides an abbreviated version here.

Five years ago, Plaintiffs Bowen Uhlenkamp and Sadaf Lakhani sought relief for DCPS’s

alleged failure to provide their child—“A.U.”—a free and appropriate public education

(“FAPE”) in violation of the IDEA. Id. at 234. They claimed that DCPS failed to develop an

individualized education plan (“IEP”) that adequately addressed A.U.’s learning disabilities. Id.

at 231. In line with IDEA’s requirement that Plaintiffs exhaust administrative remedies before

suing in federal court, see Massey v. District of Columbia, 400 F. Supp. 2d 66, 70 (D.D.C. 2005),

Plaintiffs started their challenge by filing an administrative complaint. Uhlenkamp, 691 F. Supp.

3d at 234. By that time, Plaintiffs had moved A.U. to a private school, so their requested relief

included tuition for his new school and several other education-related reimbursements. Id. at

233–34. Hearing Officer Terry Michael Banks heard their case and denied relief in full. Id. at

234–35. Plaintiffs then turned to this Court, suing DCPS under the IDEA to try to undo that

decision. Id. at 235.

Following cross motions for summary judgment, this Court remanded the case to the

hearing officer to decide whether three individualized education programs (“IEPs”)—from April,

May, and December 2019—violated A.U.’s right to a FAPE and whether Plaintiffs were entitled

to tuition reimbursement. Id. at 229. On a second pass, the hearing officer again rejected

Plaintiffs’ challenge to the three IEPs and thus declined to impose tuition reimbursement. See

Remand Administrative Record (“RAR”) at 57–58, ECF No. 66-1. Plaintiffs once more seek to

reverse the hearing officer’s decision. See generally Supplemental Compl., ECF No. 63. After

2 the Court referred the case to a magistrate judge for full case management, both parties again

moved for summary judgment. Pls.’ Mot. for Summ. J., ECF No. 67-1; Defs.’ Cross Motion for

Summ. J., ECF No. 70.

In his Report considering these cross motions, Magistrate Judge Matthew J. Sharbaugh

recommended granting and denying both motions in part. Report, ECF No 74. While he found

two of three IEPs insufficient to meet DCPS obligations under the IDEA, Magistrate Judge

Sharbaugh agreed with DCPS that the third IEP (from December 2019) appropriately addressed

A.U.’s needs. Id. at 15, 17, 22. Because Plaintiffs’ tuition reimbursement claims were tethered

only to the December IEP, the magistrate judge also recommended denying that request. Id. at

23–24.

Now before the Court are the parties’ summary judgment motions, the Report, and

Plaintiffs’ seven objections to it. Pls.’ Objections, ECF No. 77. They challenge Magistrate

Judge Sharbaugh’s conclusions about only the December IEP (and thus also tuition). Id. Neither

party objects to the other two-thirds of the Report.

Upon consideration of the Report, Plaintiffs’ objections, the District’s response, the

summary judgment briefing, and the entire record, the Court will adopt the findings and

conclusions of the Report in full. It will thus grant in part and deny in part both parties’

summary judgment motions. The Court provides supplemental analysis only in response to

Plaintiffs’ objections about the December IEP and otherwise incorporates by reference

Magistrate Judge Sharbaugh’s Report.

II.

A few sets of rules govern this Court’s review. First are those guiding summary

judgment in the IDEA setting. Although styled as motions for summary judgment, the Court

3 treats the cross-motions before it as seeking review of Hearing Officer Banks’ administrative

determination. See S.B. v. District of Columbia, 783 F. Supp. 2d 44, 50 (D.D.C. 2011). That is

because, when neither party puts forth additional evidence, a summary judgment motion in this

setting operates as the “the procedural vehicle for asking the judge to decide the case on the basis

of the administrative record.” M.G. v. District of Columbia, 246 F. Supp. 3d 1, 8 (D.D.C. 2017)

(cleaned up).

The Court “must give due weight to the administrative proceedings and afford some

deference to the expertise of the hearing officer and school officials responsible for the child’s

education.” Gill v. District of Columbia, 751 F. Supp. 2d 104, 109 (D.D.C. 2010) (cleaned up);

Roark ex rel. Roark v. District of Columbia, 460 F. Supp. 2d 32, 38 (D.D.C. 2006). Indeed, “a

hearing officer’s findings based on credibility determinations of live witness testimony are given

particular deference where there is no supplementation of the record.” McAllister v. District of

Columbia, 45 F. Supp. 3d 72, 76 (D.D.C. 2014) (cleaned up). That said, a hearing decision that

lacks “reasoned and specific findings deserves little deference.” Kerkam v. Superintendent of

D.C. Pub. Schs., 931 F.2d 84, 87 (D.C. Cir. 1991) (cleaned up).

Next are rules for reviewing objections to a magistrate judge’s recommendation. Under

Federal Rule of Civil Procedure

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Related

Block v. District of Columbia
748 F. Supp. 891 (District of Columbia, 1990)
S.B. v. District of Columbia
783 F. Supp. 2d 44 (District of Columbia, 2011)
Roark Ex Rel. Roark v. District of Columbia
460 F. Supp. 2d 32 (District of Columbia, 2006)
Schoenbach v. District of Columbia
309 F. Supp. 2d 71 (District of Columbia, 2004)
Massey v. District of Columbia
400 F. Supp. 2d 66 (District of Columbia, 2005)
A.I. Ex Rel. Iapalucci v. District of Columbia
402 F. Supp. 2d 152 (District of Columbia, 2005)
Wesleyann & Warren Gill v. District of Columbia
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Shurtleff v. United States Environmental Protection Agency
991 F. Supp. 2d 1 (District of Columbia, 2013)
L.R.L. Ex Rel. Lomax v. District of Columbia
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McAllister v. District of Columbia
45 F. Supp. 3d 72 (District of Columbia, 2014)
Antoine Jones v. Steve Kirchner
835 F.3d 74 (D.C. Circuit, 2016)
Garris v. District of Columbia
210 F. Supp. 3d 187 (District of Columbia, 2016)
M.G. v. District of Columbia
246 F. Supp. 3d 1 (District of Columbia, 2017)
Goodman v. Colvin
233 F. Supp. 3d 88 (District of Columbia, 2017)
Z. B. v. Dist. of Columbia
888 F.3d 515 (D.C. Circuit, 2018)
Edward M.R. v. DC
128 F.4th 290 (D.C. Circuit, 2025)

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