J.K. v. Council Rock School District
2011 U.S. Dist. LEXIS 143660
| E.D. Pa. | 2011Background
- J.K. is a student with a learning disability; M.K. and F.K. are her parents; Council Rock is the LEA responsible for providing FAPE under IDEA; plaintiffs challenge a state- administrative decision and pursue a related state-law contract claim; Hearing Officer Culleton issued findings on August–October 2010 and denied enforcement of a settlement and found the District provided FAPE; plaintiffs moved for judgment on the administrative record and sought to enforce the settlement agreement and obtain relief on the contract claim; the court deferentially reviews the IDEA decision and applies summary-judgment standards to contract claims; the court ultimately denies the motion and orders further briefing on the contract claim and potential dismissal; the key dispute involves settlement enforceability, pendent placement under stay-put, and whether the 2009 March IEP offered for 2010-2011 was timely and appropriate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Hearing Officer had jurisdiction to enforce a settlement agreement. | Plaintiffs argue the IDEA allows enforcement of settlement agreements; they seek to enforce the September 2009 agreement. | District argues Hearing Officer lacks jurisdiction to enforce settlement contracts under the IDEA. | Hearing Officer lacked jurisdiction to enforce the settlement agreement. |
| What constitutes J.K.’s pendent placement stay-put for this litigation. | Plaintiffs contend the pendent placement should reflect the March 2009 IEP as last proposed by the District. | District argues the pendent placement is defined by the settlement language and last proposed program. | Court must not enforce the settlement-based pendent placement; interpret the stay-put provision independently. |
| Whether the March 2009 IEP offered for 2010-2011 was timely and appropriate. | Plaintiffs contend no timely or proper offer occurred for 2010-2011 beyond the March 2009 IEP. | Defendant contends the March 2009 IEP re-offered in March 2010 was timely and appropriate. | March 2009 IEP re-offered March 30, 2010 was timely and appropriate for 2010-2011. |
| Whether the breach-of-contract claim survives given the settlement terms and governing law. | Settlement created a contractual obligation; parents seek damages and enforcement. | Agreement terms do not impose the asserted duties; contract claim limited by Stay-put and other provisions. | The contract claim survives the court’s analysis but requires further proceedings; summary judgment denied. |
Key Cases Cited
- Shore Reg’l High Sch. Bd. of Educ. v. P.S., 381 F.3d 194 (3d Cir.2004) (deference to state-fact findings; special weight to credibility findings)
- S.H. v. State-Operated Sch. Dist. of City of Newark, 336 F.3d 260 (3d Cir.2003) (deference to administrative record under IDEA; preponderance standard)
- Oberti v. Bd. of Educ. of Borough of Clementon Sch., 995 F.2d 1204 (3d Cir.1993) (two-pronged inquiry for FAPE: procedures and reasonably calculated benefits)
- Bd. Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (1982) (educational policy not to maximize potential but provide meaningful education)
- D.R. v. E. Brunswick Bd. of Educ., 109 F.3d 896 (3d Cir.1997) (settlement agreements should be enforced as written; contracts govern breach questions)
- Ballard v. Phila. Sch. Dist., 273 Fed.Appx. 184 (3d Cir.2008) (settlement waivers may be enforced; courts may view settlement terms as binding contracts)
- H.C. v. Colton-Pierrepont Cent. Sch. Dist., 341 Fed.Appx. 687 (2d Cir.2009) (hearing officers lack authority to enforce settlement agreements; may consider terms related to FAPE)