S.P. v. Mamaroneck Union Free School District

S.P. was a child with autism who attended regular-education preschool part-time in the Mamaroneck Union Free School District (the district) (defendant) and also received special-education services funded by the district at his home. S.P.’s parents (plaintiffs) and the district began the process of developing an individualized education program (IEP) for S.P. for kindergarten. The district engaged a consultant to evaluate S.P. and make recommendations regarding S.P.’s placement and services. S.P.’s parents also hired consultants to perform a similar evaluation and make recommendations. There were significant differences between the two sets of recommendations. Based on the district’s consultant’s evaluations, the district recommended placing S.P. in a special-education class with shared aides and additional therapy a few times a week in school, while S.P.’s parents requested that S.P. have a personal aide in the classroom and continue receiving significant hours of various therapies at home. The district made some concessions to S.P.’s parents, but the final IEP aligned more closely with the district’s consultant’s recommendations than those of the parents’ consultants. S.P.’s parents objected to the IEP, decided to supplement S.P.’s services with continued in-home therapies, and filed an administrative appeal to obtain reimbursement from the district for those services. S.P.’s parents alleged that the district had violated the Individuals with Disabilities Education Act (IDEA) by improperly predetermining S.P.’s IEP. The administrative-hearing officer denied their claim, and S.P.’s parents appealed in federal district court. The district court held that the district had violated the IDEA and granted summary judgment and reimbursement to S.P.’s parents. The district appealed.