Los Angeles Unified School District v. Garcia
2012 U.S. App. LEXIS 1179
9th Cir.2012Background
- Garcia, 21, incarcerated in LA County Jail awaiting trial; mother resides within LAUSD.
- Garcia has a learning disability and speech-language impairment, qualifying for IDEA services.
- Garcia received special education pre-incarceration and in a juvenile facility, but stopped after turning 18.
- OAH and district court concluded LAUSD was the responsible district under Cal. Educ. Code § 56041.
- The certified question asks whether § 56041 applies to incarcerated adults in county jails; no controlling authority exists.
- The Ninth Circuit stayed proceedings and certified the question to the California Supreme Court to determine California-law allocation of responsibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does § 56041 apply to incarcerated adults in county jails? | Garcia argues § 56041 broadly assigns the district of residence. | LAUSD argues no delegation exists for incarcerated adults; state default governs. | Certified question; court will defer to California Supreme Court. |
Key Cases Cited
- Union Sch. Dist. v. Smith, 15 F.3d 1519 (9th Cir. 1994) (determines state-law allocation of IDEA responsibilities (general rule))
- Orange Cnty. Dep't of Educ. v. California Dep't of Educ., 668 F.3d 1052 (9th Cir. 2011) (state authority to assign responsibility; statutory interpretation in correctional context)
- Katz v. Los Gatos-Saratoga Joint Union High Sch. Dist., 117 Cal.App.4th 47 (Cal. App. 2004) (parental residence generally governs school district; exceptions noted)