Dracut School Committee v. Bureau of Special Education Appeals of the Massachusetts Department of Elementary and Secondary Education

CA (plaintiff) was a disabled student at Dracut High School (Dracut) (defendant) who struggled with social interactions in and out of the classroom due to Asperger’s syndrome, anxiety, and bipolar disorder. As required by the Individuals with Disabilities Education Act (IDEA), Dracut developed an individualized education program (IEP) for CA for each of his school years. When CA turned 16, his IEPs began including content related to postschool transition services. The first two of these IEPs noted CA’s goals for after graduation, but neither included assessments of CA’s postschool capabilities. The third IEP included a two-day vocational assessment that evaluated CA in a catering work environment. A year later, CA was provided an internship in the school credit union, but no specific services or goals were implemented related to CA’s social difficulties, postschool education options, or life skills. CA did not receive a vocational placement in the community. CA was put in a social-skills class and counseling, but the staff did not address CA’s pragmatic language difficulties or independent-living skills like self-hygiene and transportation navigation. CA requested a due-process hearing, and the hearing officer found that Dracut’s IEPs denied CA a free appropriate public education (FAPE) under the IDEA. The hearing officer ordered Dracut to issue CA a diploma and to provide compensatory education for two years. Dracut sought review in district court. Both parties filed for summary judgment.