"Every person carries within them an inherent purpose and wisdom;
our task is to create conditions where this can flourish." Christine English
"Every person carries within them an inherent purpose and wisdom;
our task is to create conditions where this can flourish." Christine English
The cases below demonstrate ongoing legal challenges and efforts to improve special education services for students in California and nationwide. They address various aspects of special education, from specific learning disabilities to broader systemic issues in identification, evaluation, and services provisions. Each of these cases has contributed to shaping special education services, policies and practices.
Although this case originated in Rhode Island, it has had implications for California and other states. The lawsuit argued that students with disabilities were not receiving adequate civic education, which is crucial for meaningful participation in democracy. While not specific to California, this case has influenced discussions about civic education for students with disabilities nationwide.
Endrew F. v. Douglas County School District (2017)
Another Supreme Court case with significant implications for California, it raised the standard for what constitutes an "appropriate" education under IDEA. The Court held that schools must offer an IEP "reasonably calculated to enable a child to make progress appropriate in light of the child's circumstances."
This lawsuit focused on literacy education for all students, including those with disabilities. While not exclusively about special education, it had significant implications for students with disabilities who were struggling with reading. The case resulted in a settlement in 2020 that required the state to provide additional funding and support for literacy programs in low-performing schools.
Fry v. Napoleon Community Schools (2017)
While this is a U.S. Supreme Court case, it has implications for California. It clarified when parents must exhaust administrative remedies under IDEA before filing lawsuits under other federal laws like the ADA or Section 504 of the Rehabilitation Act.
This class action lawsuit alleged that the Oxnard School District systematically failed to identify, evaluate, and provide services to students with disabilities, particularly those with dyslexia. The case resulted in a settlement agreement requiring the district to improve its special education services.
Timothy O. v. Paso Robles Unified School District (2016)
This case reinforced the importance of school districts' Child Find obligations. The Ninth Circuit (which includes California) ruled that the district violated IDEA by failing to assess a student for autism despite clear signs of the condition.
L.J. v. Pittsburg Unified School District (2016)
This Ninth Circuit (which includes California) case emphasized the importance of considering both academic and behavioral needs in IEPs. The court found that the school district denied FAPE by failing to address a student's maladaptive behaviors in his IEP.
This case dealt with the provision of applied behavior analysis (ABA) therapy for students with autism. The court ruled that the school district's failure to consider the parents' request for ABA therapy was a procedural violation of IDEA that resulted in substantive harm to the student.
This case challenged the California High School Exit Exam (CAHSEE) requirement for students with disabilities. The lawsuit argued that the exam discriminated against students with disabilities and denied them equal educational opportunities. As a result of this and other legal pressures, California eventually suspended the CAHSEE requirement for all students in 2015.
This case addressed the provision of nursing services to students with disabilities. The Ninth Circuit Court of Appeals (which includes California) ruled that the school district must provide prescribed nursing services to a student with disabilities during the school day as part of his Individualized Education Program (IEP).
While not a California case, this Ninth Circuit decision (which includes California) emphasized the importance of parental participation in IEP meetings. The court ruled that the school district violated IDEA by holding an IEP meeting without the parent present, even though the meeting was held to comply with statutory deadlines.
E.R.K. v. Hawaii Department of Education (2013)
Another Ninth Circuit case relevant to California, this decision held that states must provide a free appropriate public education (FAPE) to students with disabilities until they receive a regular high school diploma or age out of eligibility, even if state law limits education to a younger age for non-disabled students.
This case addressed the interplay between the IDEA and the Americans with Disabilities Act (ADA) in providing communication access to students who are deaf or hard of hearing. The Ninth Circuit ruled that compliance with IDEA does not necessarily establish compliance with the ADA, potentially requiring schools to provide additional accommodations.
Smith v. Los Angeles Unified School District (2013)
This case (not to be confused with the earlier Chanda Smith case) focused on the district's alleged failure to provide appropriate behavior support plans for students with disabilities. It resulted in a settlement agreement requiring LAUSD to improve its behavior support services.
This case dealt with Child Find obligations and the importance of considering all areas of suspected disability. The Ninth Circuit Court ruled that school districts must assess students in all areas of suspected disability and that failing to do so is a procedural violation of the IDEA that may result in substantive harm.
This case was initially filed in 2011 and has had ongoing implications for special education in California. The suit was brought by the Morgan Hill Concerned Parents Association and the Concerned Parents Association (now known as the California Concerned Parents Association).
The lawsuit alleged that the California Department of Education (CDE) failed to monitor and ensure that school districts throughout the state were providing appropriate special education services as required by federal law, particularly the Individuals with Disabilities Education Act (IDEA). Unlike the Chanda Smith case which focused on LAUSD, this lawsuit has statewide implications, potentially affecting all school districts in California.
In 2016, the case gained significant attention due to a court order that could have required the CDE to release sensitive student data. This led to widespread concern about student privacy.
In 2020, a consent decree was reached, requiring the CDE to make significant changes to its monitoring and support systems for special education programs statewide. This case represents a more recent and broader challenge to special education practices in California compared to the earlier Chanda Smith case, which was specific to LAUSD. It highlights ongoing concerns about the implementation and oversight of special education services at a state level.
As of the last update in 2023, this case was still active and continues to influence discussions about special education oversight, data management, and compliance monitoring in California.
N.D. v. Hawaii Department of Education (2010)
Although not a California case, this Ninth Circuit decision (which includes California) addressed the "stay put" provision of IDEA. The court ruled that the provision applies to students transitioning from early intervention services to school-aged services, ensuring continuity of services during disputes.
This case was filed against the California Department of Education and the Ravenswood City School District. It alleged systemic failures in providing appropriate special education services to students in the district. The case resulted in a consent decree that mandated comprehensive reforms in the district's special education program.
The consent decree is related to special education in the Los Angeles Unified School District (LAUSD) and is known as the Chanda Smith Consent Decree.
This consent decree was the result of a class action lawsuit filed in 1993 on behalf of Chanda Smith, a student with learning disabilities, and other students with disabilities in LAUSD. The lawsuit alleged that the district was failing to provide adequate special education services as required by federal law.
The Chanda Smith Consent Decree was implemented in 1996 and remained in effect for over two decades. It required LAUSD to make significant improvements in its special education programs and services, including timely assessments, appropriate placements, and better record-keeping.
The consent decree was officially terminated in 2019 after the district demonstrated substantial compliance with its requirements. However, the impact of this decree on special education practices in LAUSD has been long-lasting.