Cupertino Union School District v. K.A., 5:13-cv-04659

K.A. is a 12-year-old with regressive autism eligible as a student with autistic-like behaviors.
In April 2012, K.A. suffered seizures; the district denied a 1:1 aide but invited an IEP meeting to discuss needs.
May 31, 2012, an emergency IEP was held; district required a doctor’s note to place a student on home-hospital instruction and did not offer it absent such note.
The district offered an aide for the full school day but no bus aide; no home-hospital instruction was provided at that meeting.
A June 8, 2012 IEP superseded the May 31 offer; the court later found issues with the May 31 decision.
The Court affirmed the ALJ’s ruling that there was no deprivation of FAPE on May 31, 2012 due to lack of a compliant physician’s note.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the District deny FAPE by denying home-hospital instruction on May 31, 2012?	Father argues reliance on district’s 1:1 aide offer excused the note.	District required a compliant medical report before home instruction could be recommended.	Issue affirmed; no FAPE denial due to lack of compliant medical note.

E.M. ex rel. E.M. v. Pajaro Valley Unified Sch. Dist. Office of Admin. Hearings, 652 F.3d 999 (9th Cir. 2011) (preeminent standard for handling additional evidence and deference in IDEA appeals)
Van Duyn ex rel. Van Duyn v. Baker Sch. Dist. 5J, 481 F.3d 770 (9th Cir. 2007) (due weight to state proceedings and credibility findings)
Ojai Unified Sch. Dist. v. Jackson, 4 F.3d 1467 (9th Cir. 1993) (requirement to give deference to hearing officer’s determinations)
Capistrano Unified Sch. Dist. v. Wartenberg, 59 F.3d 884 (9th Cir. 1995) (practical approach to evaluating administrative decisions)
Union Sch. Dist. v. Smith, 15 F.3d 1519 (9th Cir. 1994) (thorough and careful findings warrant deference)
Amanda J. ex rel. Annette J. v. Clark Cnty. Sch. Dist., 267 F.3d 877 (9th Cir. 2001) (credibility evaluations in live-witness testimony)
Schaffer ex rel. Schaffer v. Weast, 546 U.S. 49 (2005) (broader burden-shifting framework in IDEA context)