Andra Barton (defendant) was a principal at Old Union Elementary School. In an effort to improve test scores at the school, particularly among students with disabilities, Barton developed a new educational plan. The Individuals with Disabilities Education Act and its corresponding state regulations required Barton to provide written notice of program changes to affected parents of students with disabilities. Barton arranged for affected parents to receive oral notice. The State Board for Educator Certification (Board) (plaintiff) brought disciplinary charges against Barton. The Board’s petition alleged violations of certain laws and regulations. The petition specifically alleged Barton altered students’ educational programs without following proper procedures and failed to notify affected parents of the changes. An administrative law judge found Barton failed to give written notice to affected parents. A trial court affirmed. Barton appealed, arguing the failure to give written notice was never pled against her.