CD v. Natick Public School District

CD (plaintiff) was a student in the Natick Public School District (district) (defendant) who had an intellectual disability and significant deficits in language ability. CD was considered disabled under the Individuals with Disabilities Education Act (IDEA). Before CD entered high school, the district met with CD’s parents to develop an individualized education program (IEP) for CD. CD had previously attended a private school and participated in regular education classes with the assistance of private tutors. The district worried about CD’s transition to high school due to larger class sizes and more advanced content. After considering multiple placement options, the district proposed an IEP that put CD in regular classrooms for her electives and in the district’s ACCESS program for her academic courses. The ACCESS program was a special education program with a modified curriculum that was designed for students with cognitive disabilities. CD’s parents rejected the IEP as an overly restrictive environment that would hinder her academic and social development. CD enrolled in a private prep school instead. The district offered two new IEPs with ACCESS program components, and CD’s parents rejected both, opting to continue private school education for two more years. CD’s parents filed an IDEA complaint against the district, seeking private school tuition reimbursement. CD’s parents argued that the IEPs violated the IDEA’s least-restrictive-environment requirement and did not include required postschool-transition assessments and plans. A hearing officer found that the IEPs met the IDEA’s requirements, and CD’s parents appealed the decision in a federal district court. The district court affirmed the hearing officer’s decision, and CD’s parents appealed to the First Circuit. The appellate court found that the IEPs contained sufficient transition assessments and then addressed the issue of the least restrictive environment.