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J.P. v. County School Board of Hanover County

516 F.3d 254 (2008)

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J.P. v. County School Board of Hanover County

United States Court of Appeals for the Fourth Circuit
516 F.3d 254 (2008)

  • Written by Jody Stuart, JD

Facts

J.P. was a young boy with autism. J.P.’s parents (plaintiffs) sought a due-process hearing to determine whether the individualized education program (IEP) developed for J.P. by the County School Board of Hanover County, Virginia (Hanover) (defendant) was adequate under the requirements of the Individuals with Disabilities Education Act (act). After considering the evidence presented during the hearing, the hearing officer concluded that the IEP was appropriate under the act. The hearing officer’s 25-page opinion included summaries of expert-witness testimony, an outline of the relevant legal standards, and the hearing officer’s findings of fact and legal conclusions. The summaries of witnesses’ testimony were each one to two pages and captured the essence of the testimony on the central issues of the case. J.P’s parents appealed. The federal district court concluded that deference to the hearing officer’s findings was not required because the hearing officer’s opinion was insufficiently detailed. The district court criticized the hearing officer’s summaries of testimony as terse and conclusory and claimed that the opinion failed to recite the experts’ opinions and completely lacked written analysis. The district court found that the IEP was inappropriate. Hanover appealed.

Rule of Law

Issue

Holding and Reasoning (Traxler, J.)

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