Crofts v. Issaquah School District, No. 19-35473 (9th Cir. 2022)
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Crofts requested that the School District evaluate her daughter, A.S., for special-education services after she received an outside evaluation indicating that A.S. might have dyslexia. The District evaluated A.S. under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1401(30). enumerated “specific learning disability” category, which encompasses conditions like dyslexia. It determined that she was eligible for services in reading and writing and created an individualized education plan (IEP) targeting A.S.’s deficiencies in those areas. Crofts argued that the District should have evaluated A.S. specifically for dyslexia and used her preferred teaching method for dyslexia, and that it improperly denied her request for an independent educational evaluation.
A Washington State ALJ found that the District did not violate the IDEA. The district court and Ninth Circuit affirmed. The ALJ properly discounted expert witness testimony. The District satisfied the IDEA by evaluating A.S. under the “specific learning disability” category and did not violate its obligation to evaluate the student in “all areas of suspected disability” when it did not formally evaluate her for dyslexia. The District’s IEPs were reasonably calculated to help the student progress; the District did not deny a FAPE by failing to use the parents’ preferred teaching method.
Court Description: Individuals with Disabilities Education Act Affirming the district court’s summary judgment in favor of a school district in an action under the Individuals with Disabilities Education Act, the panel held that the school district properly denied a student’s parent’s request for an independent educational evaluation, properly evaluated the student for an individualized education plan, and did not deny the student a free appropriate public education. Affording deference to a state administrative law judge, the panel held that the ALJ properly discounted expert witness testimony. The panel held that the school district satisfied the IDEA by evaluating the student for a “specific learning disability,” and the school district did not violate its obligation to evaluate the student in “all areas of suspected disability” when it did not formally evaluate her for dyslexia. The panel * The Honorable Jennifer A. Dorsey, United States District Judge for the District of Nevada, sitting by designation. CROFTS V. ISSAQUAH SCHOOL DISTRICT NO. 411 3 further held that the school district’s IEPs were reasonably calculated to help the student progress, and the school district did not deny her a FAPE by failing to use her parents’ preferred teaching method.
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