Fairfield-Suisun Unified School District v. State of California Department of Education
780 F.3d 968
9th Cir.2015Background
- Two California local educational agencies (school district and county office of education) sued the California Department of Education (CDE), alleging routine procedural violations of the Individuals with Disabilities Education Act (IDEA) in complaint resolution proceedings.
- The complaints arose after parents filed IDEA complaints with CDE and CDE issued written decisions favorable to the parents; school districts challenged CDE’s procedures (e.g., multiple reconsiderations, application of a 1-year limitations period, and allocation of burden of proof).
- Complaint resolution proceedings are one of two IDEA-required dispute mechanisms; unlike due process hearings, the IDEA and regulations do not expressly provide for judicial review of complaint resolution decisions.
- Plaintiffs sought declaratory and injunctive relief to prevent CDE’s allegedly unlawful procedures from recurring; district courts dismissed both suits with prejudice, holding school districts lack a right to sue state agencies for IDEA procedural violations.
- The Ninth Circuit considered whether the IDEA (specifically 20 U.S.C. § 1415(i)(2)(A)) creates an express or implied private right of action for school districts to challenge state agencies’ compliance in complaint resolution proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether school districts have a private right of action under the IDEA to sue a state education agency over procedural violations in complaint resolution proceedings | School districts argued the IDEA implies a private right to sue under §1415(i)(2)(A) to enjoin recurring, unlawful complaint-resolution practices | CDE argued the IDEA does not grant school districts an express or implied right to litigate procedural compliance for complaint resolution proceedings | Court held no express or implied private right exists; Lake Washington controls and bars recognizing such an implied cause of action for school districts |
| Whether the cases were moot given CDE’s concessions and compliance | School districts argued claims fall within the capable-of-repetition-yet-evading-review exception and are not moot | CDE contended the suits were moot because it agreed not to enforce / school district complied | Court held the claims are not moot under the capable-of-repetition-yet-evading-review exception |
Key Cases Cited
- Lake Wash. Sch. Dist. No. 414 v. Office of Superintendent of Pub. Instruction, 634 F.3d 1065 (9th Cir. 2011) (held school districts have no implied private right under IDEA to sue state agencies over procedural compliance)
- Porter v. Jones, 319 F.3d 483 (9th Cir. 2003) (discusses the capable-of-repetition-yet-evading-review exception to mootness)
- Rosemere Neighborhood Ass’n v. EPA, 581 F.3d 1169 (9th Cir. 2009) (mootness and capable-of-repetition principles)
- M.M. v. Lafayette Sch. Dist., 681 F.3d 1082 (9th Cir. 2012) (background on IDEA due process hearings and procedures)
Decision: AFFIRMED. The Ninth Circuit affirmed dismissal because school districts lack an express or implied private right of action under the IDEA to challenge state complaint-resolution procedures; mootness exception applied so claims were not moot.