Compton Unified School District v. Addison

Starvenia Addison (plaintiff) was a high school student in the Compton Unified School District (district) (defendant). In her ninth-grade year, Addison academically performed at a fourth-grade level, earning poor grades and scoring below the first percentile on standardized tests. The school counselor attributed Addison’s difficulties to the high school transition, and Addison continued to her tenth-grade year, during which she failed every academic subject. Teachers reported that Addison turned in papers of gibberish, colored with crayons, played with dolls, and occasionally soiled herself in class. Addison’s mother was hesitant to have Addison formally assessed, and the district did not push. Instead, Addison was sent to an outside mental health counselor, who recommended that the district assess Addison for learning disabilities. The district refused and pushed Addison into eleventh grade. Addison’s mother formally requested that the district conduct an educational assessment and hold an individualized education program (IEP) meeting for Addison. Three months later, the district assessed Addison, and after another month had passed, the IEP team found Addison eligible for special education services. Addison filed a complaint under the Individuals with Disabilities Education Act (IDEA), alleging that the district failed to meet its Child Find requirement. The administrative-law judge found in favor of Addison at the due-process hearing, and a district court affirmed the judgment on appeal. The district appealed the case again to the Ninth Circuit. Although the IDEA required educational agencies to provide written notice if initiating or refusing to initiate a child’s identification or evaluation, the district argued that Addison was not entitled to written notice and thus had no right to file her claim.