Background
P.H., a minor with serious medical issues, attended school in the Compton Unified School District. After P.H. began experiencing medical issues, the district did not provide an individualized education program but instead summarily disenrolled her. P.H. and her mother sought relief under the Individuals with Disabilities Education Act. An administrative law judge initially denied relief, but the district court reversed. On remand, the administrative law judge found that the district had denied P.H. a free appropriate public education. The district court affirmed that order and awarded attorney’s fees. The district now appeals the merits decision and the fee award.
The court’s reasoning
The court reviewed questions of law de novo and factual findings for clear error. It held that the administrative law judge had jurisdiction to adjudicate residency because it was intertwined with the IDEA claim. The court affirmed that the district denied a free appropriate public education because the inter-district permit remained valid and the district’s summary disenrollment and failure to provide an IEP constituted a procedural violation. The court rejected the district’s argument that it was not liable because the student was hospitalized, noting that no other district had responsibility for a student who had not yet been identified as having a disability. Regarding fees, the court found no abuse of discretion in the award, as the plaintiffs succeeded in showing the denial of a free appropriate public education, which is the most significant success possible under the Act.
What it means going forward
School districts must ensure that students with disabilities are not summarily disenrolled and that individualized education programs are provided in a timely manner, regardless of residency disputes or hospitalization status. The ruling reinforces that procedural violations under the Individuals with Disabilities Education Act can result in significant attorney’s fee awards when plaintiffs achieve the core relief sought.