LJ by NNJ v. School Board of Broward County

LJ (plaintiff), a child with autism and a speech impediment, was a student in the Broward County school system from kindergarten until seventh grade. In third grade, school officials worked with LJ’s mother to create and implement an individualized education program (IEP) for LJ as required by the Individuals with Disabilities Education Act (IDEA). In sixth grade, LJ exhibited severe behavioral issues, and the School Board of Broward County (board) (defendant) proposed a new IEP to accommodate the middle school transition. LJ’s mother filed an IDEA complaint to challenge the content of the proposed IEP and invoked the IDEA’s stay-put provision to reinstate the elementary school IEP until her challenges were resolved. LJ’s mother filed numerous additional complaints regarding the new IEP’s content. An administrative-law judge (ALJ) eventually ruled that the new IEP’s content was appropriate and that the board had adequately implemented the elementary school IEP during the administrative proceedings. LJ’s mother appealed the decision to a district court, which affirmed it. During the time between the ALJ’s decision and the district court’s affirmation, LJ continued to exhibit behavioral issues, and LJ’s mother filed another complaint alleging that the board failed to implement the elementary school IEP during the federal court proceedings. An ALJ found that the board had failed to implement significant provisions of the IEP during the court period, and both parties filed claims in district court, LJ’s mother seeking enforcement of the ALJ’s order and additional relief and the board challenging the order. The district court reversed the ALJ’s decision, and LJ’s mother appealed to the Eleventh Circuit.