D.L. and K.L., o/b/o J.L. v. Springfield Board of Education

The Individuals with Disabilities Education Act (act) required school districts to provide a free, appropriate public education (FAPE) through an individualized education program (IEP) for each student designated as eligible for special education. J.L. was diagnosed with autism-spectrum disorder at age two. J.L. attended a mainstream preschool for nondisabled children. The Springfield Board of Education (Springfield) (defendant) determined that J.L. was eligible for special-education services. D.L. and K.L. (plaintiffs), J.L.’s parents, participated in the development of an IEP for J.L. The finalized IEP offered to place J.L. in a preschool disabled class. J.L.’s parents provided Springfield with written notice of their rejection of the IEP and of their intent to seek additional special-education services for J.L. J.L.’s parents also provided Springfield with written notice of their intent to seek reimbursement for the special-education services. J.L.’s parents were concerned that placing J.L. in a preschool disabled class would negate the progress he had made attending a mainstream preschool class. J.L.’s parents requested a due-process hearing, alleging that the IEP was inadequate and seeking reimbursement for expenses related to J.L.’s education. J.L. had not received any special-education services from Springfield. Springfield filed a motion to dismiss the claim for reimbursement, and the administrative-law judge dismissed the case without a hearing. J.L.’s parents appealed.