R.B. v. St. Mary's County Board of Education, 8:24-cv-00762

H.R.B., a minor with learning and mental health disabilities, attended St. Mary’s County Public Schools (SMCPS) through eighth grade when parents sought special education services.
After evaluations, SMCPS classified her as eligible for special education under ADHD and later also for a Specific Learning Disability; parents pressed for more restrictive educational settings, citing significant trauma and PTSD.
Disputes arose over H.R.B.’s Individualized Education Program (IEP), particularly the placement—inclusive vs. full-time special education—and implementation delays.
Parents unilaterally enrolled H.R.B. in a private special education school and sought SMCPS-funded tuition reimbursement, arguing public programs were inadequate.
An Administrative Law Judge (ALJ) found no denial of a Free and Appropriate Public Education (FAPE), and the parents filed suit in federal court under IDEA.
Both sides moved for summary judgment; the court reviewed the ALJ’s findings under a “modified de novo review,” giving deference to regularly made factual findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the proposed IEP deny H.R.B. a FAPE?	IEP insufficient, did not address unique needs; full-time specialized setting required.	IEP provided substantial specialized services and incorporated expert input; LRE met, some general ed appropriate.	No denial of FAPE; IEP was reasonably calculated to provide educational benefit and met legal requirements.
Was H.R.B.'s placement predetermined (procedural IDEA violation)?	Placement was predetermined before parent input; parent participation denied.	Placement discussed openly in IEP meetings; parents had opportunities for input; IEP revised repeatedly per feedback.	No predetermination; parents participated, record shows revisions, and even if error, no loss of FAPE.
Did the failure to have an IEP in place at start of school year deny H.R.B. a FAPE?	Procedural violation caused educational loss; school’s delay prejudicial.	Parents caused delays, withheld info, and would have refused any IEP without private placement.	No denial of FAPE; parents would have rejected all but private placement; reimbursement not warranted.
Are factual findings of the ALJ entitled to deference?	ALJ’s credibility findings were flawed and ignored key evidence.	Factual findings were regularly made, thorough, not arbitrary; deference required.	ALJ’s findings regularly made; court defers to them absent procedural irregularity.

Bd. of Educ. of the Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (defining "some educational benefit" standard for FAPE under IDEA)
Sch. Comm. of Burlington v. Dep’t of Educ., 471 U.S. 359 (setting parameters for parental reimbursement when FAPE is denied)
M.M. ex rel. DM v. Sch. Dist. of Greenville Cnty., 303 F.3d 523 (importance of deference to ALJ findings in IDEA cases)
Doyle v. Arlington Cnty. Sch. Bd., 963 F.2d 100 (describes "modified de novo review" and primacy of regularly made ALJ findings)
Endrew F. ex rel. Joseph F. v. Douglas Cnty. Sch. Dist. RE-1, 137 S. Ct. 988 (clarifies the "reasonably calculated" standard for an appropriate IEP)