Anchorage Sch. Dist. v. M.P.

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M.P., a student with disabilities, appealed the district court's ruling that the Anchorage School District (ASD) did not deny him a free and appropriate public education (FAPE) because the failure to develop an updated Individualized Education Program (IEP) was mostly attributable to his "parents' litigious approach." The Individuals with Disabilities Education Act (IDEA) mandates that public educational agencies review and revise annually an eligible child's IEP. The Ninth Circuit Court of Appeals reversed in part, holding (1) the district court relied on an improper basis when it declined to consider whether the ASD complied with the IDEA's substantive requirements; (2) the ASD deprived M.P. of a substantively adequate FAPE by relying on an outdated IEP to measure M.P.'s academic and functional performance and provide educational benefits to M.P.; and (3) M.P.'s parents were entitled to reimbursement for private tutoring expenses incurred in 2008 and review of the propriety of private tutoring expenses incurred in 2009. Remanded. View "Anchorage Sch. Dist. v. M.P." on Justia Law