S. Kingstown Sch. Comm. v. Joanna S., No. 14-1177 (1st Cir. 2014)
Annotate this CaseSouth Kingstown School Committee (Committee) runs one of Rhode Island’s public school districts. Rhode Island has accepted federal funding under the Individuals with Disabilities Education Act (IDEA). Appellant, the mother of P.J., a disabled child the Committee was responsible for educating, filed a due process complaint seeking additional educational services for P.J. from the Committee. The Committee settled with Appellant pursuant to a Settlement Agreement under which the Committee agreed to perform four evaluations of P.J. After Appellant demanded ten additional evaluations, the Committee filed a due process complaint of its own. A Hearing Officer ruled against the Committee, concluding that some of the evaluations of P.J. had not been appropriate. The Committee then filed suit in federal district court. The district court reversed. The First Circuit affirmed, holding (1) the district court did not err in determining that the Settlement Agreement relieved the Committee of any obligation to perform or fund one of the evaluations; and (2) the district court did not err in concluding that there was insufficient factual support for Appellant’s other evaluation request. Remanded.
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