S. C. v. Lincoln County School District, No. 21-35242 (9th Cir. 2021)
Annotate this Case
An ALJ concluded that the school district had failed to provide the student, who has Prader-Willi Syndrome, with a free appropriate public education (20 U.S.C. 1412(a)(1)(A)) because she required “total food security” to obtain a meaningful educational benefit at school. The ALJ ordered the student’s placement at the educational center, which treats students with Prader-Willi Syndrome and provides total food security at the district’s expense. After the district failed either to appeal or to comply with the order, the student’s parent sought a stay-put order. The district court denied relief.
The Ninth Circuit reversed. The Individuals with Disabilities Education Act (IDEA) stay-put provision provides that while an administrative appeal or civil action filed by an “aggrieved” party is ongoing, the student must remain in her then-current educational placement. A “party aggrieved” includes a parent who is aggrieved by a school district’s failure to either appeal or comply with a final administrative order and who seeks court enforcement of that order. The district court incorrectly interpreted the ALJ order as providing alternative remedies, rather than an immediate transfer to the educational center, where the student was to remain, at the district’s expense, until the ALJ determined that a new individualized education plan addressed the perceived inadequacies in her prior setting. Under the appropriate analysis, the ALJ order changed the student’s legal placement to the educational center. Under the IDEA’s stay-put provision, this new placement must be made and maintained.
Court Description: Individuals with Disabilities Education Act The panel reversed the district court’s denial of a student’s parent’s request for a “stay put” order under the Individuals with Disabilities Education Act and remanded for entry of a stay put order requiring the student’s placement at an educational center at the expense of the defendant school district. In due process proceedings, an administrative law judge concluded that the school district had failed to provide the student, who has Prader-Willi Syndrome, with a free appropriate public education because she required “total food security” in a schoolwide environment to obtain a meaningful educational benefit at school. As a remedy, the ALJ ordered the student’s placement at the educational center, which treats students with Prader-Willi Syndrome and provides total food security in the overall school environment, at the school district’s expense. After the school district failed either to appeal or to comply with the ALJ’s order, the student’s parent sought a stay put order in the district court. The district court denied a stay put order or preliminary injunction on the ground that the parent needed to challenge in further administrative proceedings a September 2020 individualized education program (“IEP”) not covered by the ALJ’s decision. S.C. V. LINCOLN COUNTY SCHOOL DISTRICT 3 The IDEA’s stay put provision provides that while an administrative appeal or civil action filed by a “party aggrieved” by an ALJ’s decision is ongoing, the student must remain in her then-current educational placement. The panel held that a “party aggrieved” under 20 U.S.C. § 1415(i)(2)(A) includes a parent, like the parent here, who is aggrieved by a school district’s failure to either appeal or comply with a final administrative order and who seeks court enforcement of that final administrative order. Accordingly, the parent properly sought relief in the district court. The panel held that the district court incorrectly interpreted the ALJ order as providing two alternative simultaneous remedies, rather than an immediate transfer to the educational center, where the student was to remain, at the school district’s expense, until the ALJ determined that a new IEP addressed all the perceived inadequacies in her prior setting. The panel held that the district court also erred by failing to engage in an analysis of stay put and how the ALJ order changed the student’s placement. The panel held that under the appropriate analysis, the ALJ order changed the student’s legal placement to the educational center. Accordingly, under the IDEA’s stay put provision, this new placement must be made and maintained. The panel held that because a stay put order functions as an automatic injunction, consideration of irreparable harm or other traditional preliminary injunction factors was not necessary. 4 S.C. V. LINCOLN COUNTY SCHOOL DISTRICT
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.