Avila v. Spokane School District 81, No. 14-35965 (9th Cir. 2017)
Annotate this CasePlaintiffs, parents of a student at the District, filed suit alleging claims that the District violated the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. Plaintiffs argued that the district court misapplied the statute of limitations in 20 U.S.C. 1415(f)(3)(C) to their claims that the District failed to identify their child's disability or assess him for autism in 2006 and 2007. The court concluded, as a question of first impression, that the IDEA's statute of limitations requires courts to bar only claims brought more than two years after the parents or local educational agency "knew or should have known" about the actions forming the basis of the complaint. In this case, the district court barred all claims "occurring" more than two years before plaintiffs filed their due process complaint. Therefore, the court remanded so that the district court could determine when plaintiffs knew or should have known about the actions forming the basis of their complaint.
Court Description: Individuals with Disabilities Education Act. The panel reversed the district court’s dismissal, as barred by the statute of limitations, of claims under the Individuals with Disabilities Education Act. The plaintiffs claimed that their child’s school district failed to identify his disability or assess him for autism in 2006 and 2007. Agreeing with the Third Circuit, the panel held that 20 U.S.C. § 1415(f)(3)(C) requires courts to bar only claims brought more than two years after the parents or local education agency “knew or should have known” about the actions forming the basis of the complaint. Because the district court barred all claims “occurring” more than two years before the plaintiffs filed their administrative due process complaint, the panel remanded for the district court to determine when the plaintiffs knew or should have known about the actions forming the basis of their complaint. The panel addressed another claim in a memorandum disposition filed concurrently with its opinion. AVILA V. SPOKANE SCH. DIST. 81 3
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