I.K. v. School District of Haverford Township
2013 U.S. Dist. LEXIS 118051
| E.D. Pa. | 2013Background
- This is an IDEA and ADA discrimination dispute arising from B.K. and her now twenty-year-old child I.K. against the School District of Haverford Township.
- Hearing Officer Valentini found no enforceable settlement in 2009 and later addressed I.K.’s IDEA and Section 504/ADA claims on merits.
- The District moved to supplement the administrative record and for summary judgment; B.K. cross-appealed and sought judgment on the administrative record.
- This court conducted an evidentiary hearing on August 5, 2013 and supplemented the record with testimony from Judith Gran and B.K.
- The court held promissory estoppel to enforce certain promises, and also addressed waiver/release provisions barring IDEA and discrimination claims.
- The district court affirmed the 2011 decision and vacated the 2012 decision in part, granting in part summary judgment to the District.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a valid July 2009 settlement agreement? | B.K. contends no enforceable agreement existed due to lack of consideration. | District asserts there was an in-principle agreement with consideration for releases. | No enforceable settlement existed for lack of consideration. |
| Is the District entitled to promissory estoppel despite no contract? | B.K. argues estoppel cannot override lack of consideration establishing a contract. | District argued B.K. promissorily estopped from denying promises made in 2009. | Promissory estoppel applies; enforceable to the extent of established promises. |
| Are the waiver/release provisions enforceable to bar IDEA and discrimination claims? | B.K. argues release language is unclear or unenforceable against her claims. | District contends the releases are clear, unambiguous waivers of education claims through 2010 and beyond. | Waiver/release provisions preclude B.K.'s claimed relief and bars those claims. |
| Does the District have authority to proceed or supplement the record after remand? | B.K. challenges post-remand actions as beyond scope; argues improper supplementation. | District contends hearing officer acted within IDEA authority and record supplementation is appropriate. | The hearing officer acted within authority; supplementation warranted to complete record. |
Key Cases Cited
- Guthrie v. Lady Jane Collieries, Inc., 722 F.2d 1141 (3d Cir. 1983) (affirmative ability to affirm on any supported ground)
- Bay Shore Union Free Sch. Dist. v. Rain, 485 F.3d 730 (2d Cir. 2007) (review of administrative decisions and collateral orders in IDEA context)
- D.S. v. Bayonne Bd. of Educ., 602 F.3d 553 (3d Cir. 2010) (unusual deference to administrative findings with modified de novo review)
- Susan N. v. Wilson Sch. Dist., 70 F.3d 751 (3d Cir. 1995) (admonition on admitting additional evidence in IDEA review)
- Pardini v. Allegheny Intermediate Unit, 420 F.3d 181 (3d Cir. 2005) ( futility exception to exhaustion in IDEA context)
- Stelmack v. Glen Alden Coal Co., 14 A.2d 127 (Pa. 1940) (consideration essential for contract formation; forbearance and return promise)