Renee J. v. Houston Indep School District, 913 F.3d 523

C.J., a high-school student with autism, intellectual disability (IQ 51), and ADHD, read at ~1st-grade level and had emotional regulation issues and bullying complaints.
Parents sought homebound instruction in Feb–Apr 2015 after a severe outburst; HISD required a physician form and homebound packet before an ARD could approve services.
Parents delayed providing HISD’s requested forms and updated medical documentation; HISD repeatedly urged return to school and held an ARD on April 30 that denied homebound services as unnecessary.
C.J. missed nearly all of the 2015 spring semester and missed most available ESY (summer) instruction; attendance in 9th grade was inconsistent.
Parents filed an IDEA due-process complaint; an administrative hearing officer and the district court found HISD provided a FAPE; the Fifth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ABA predetermination	HISD refused ABA and predetermined methods, denying individualized IEP.	HISD uses ABA techniques, considered parents’ input, not bound to specific pedagogy.	No predetermination; district acted with an open mind and courts should not mandate specific teaching methods.
Prior written notice re: ESY	HISD failed to provide adequate prior written notice/details of ESY, causing loss of opportunity.	HISD gave notice (voicemail/email) and sought to confirm logistics; parents chose not to enroll.	No clear error in finding adequate notice; parents did not show loss of educational opportunity.
School-refusal/bullying	HISD failed to address bullying/timely convene ARD, causing C.J. to refuse school and be denied FAPE.	HISD repeatedly contacted family, offered accommodations and supports; parents withheld C.J. and delayed paperwork.	HISD’s outreach and accommodations were reasonable; no denial of FAPE shown.
Transition plan	HISD’s multi-year focus on policing careers was inappropriate and not tailored to C.J.’s realistic postsecondary needs.	Transition goals incorporated C.J.’s interests plus measurable basic life and employment skills.	Transition plan was adequate and sufficiently individualized; did not deny FAPE.

Endrew F. v. Douglas Cty. Sch. Dist., 137 S. Ct. 988 (2017) (IEP must be reasonably calculated to enable progress appropriate to child’s circumstances)
Michael F. v. Cypress-Fairbanks Indep. Sch. Dist., 118 F.3d 245 (5th Cir. 1997) (four-factor test for IEP adequacy)
Cypress-Fairbanks Indep. Sch. Dist. v. Michael F., 118 F.3d 245 (5th Cir. 1997) (same authority cited in opinion)
Pace v. Bogalusa City Sch. Bd., 403 F.3d 272 (5th Cir. 2005) (IDEA requires provision of FAPE)
Lance v. Lewisville Indep. Sch. Dist., 743 F.3d 982 (5th Cir. 2014) (IEP meeting participants and process described)
White ex rel. White v. Ascension Parish Sch. Bd., 343 F.3d 373 (5th Cir. 2003) (parents’ right to meaningful input does not permit dictating outcomes)
Richardson Indep. Sch. Dist. v. Michael Z., 580 F.3d 286 (5th Cir. 2009) (weighing Michael F. factors)
R.P. v. Alamo Heights Indep. Sch. Dist., 703 F.3d 801 (5th Cir. 2012) (importance of substantive benefit factor)
T.K. v. N.Y. City Dep’t of Educ., 810 F.3d 869 (2d Cir. 2016) (recognizing school-refusal bullying claim under IDEA)