S.B. v. District of Columbia, 783 F. Supp. 2d 44

This IDEA case concerns reimbursement for related services as part of an IEP challenging a hearing officer's partial reimbursement award.
SB, a 12-year-old with Asperger syndrome and developmental delay, attended Lowell (2005-06 to 2007-08) receiving services including OT, speech, and psychological counseling under an IEP.
In 2006, the DCPS and parents settled, agreeing to place and fund SB at Lowell for 2005-06 with all related services listed in the February 16, 2006 due process request.
DCPS reimbursed SB’s 2005-06 tuition and the related services per the settlement but did not reimburse for 2006-07 and 2007-08; SB later enrolled at McLean for 2008-09.
On August 9, 2009, a hearing officer ordered DCPS to reimburse the related services included in the 2006 settlement (OT, speech, and psychological counseling) for 2006-07 and 2007-08, but denied reimbursement for other related services not in the settlement.
Plaintiffs sought judicial review, and the court denied their summary-judgment motion while granting DCPS summary judgment, dismissing the case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the hearing officer erred in limiting reimbursement to services in the settlement.	Boorstin argues all agreed related services must be reimbursed.	DCPS contends only services in the settlement are reimbursable.	No error; settlement controls.

Bd. of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176 (U.S. 1982) (FEPA requires educational benefit; not maximum stimulus)
Reid ex rel. Reid v. District of Columbia, 401 F.3d 516 (D.C. Cir. 2005) (review standard under IDEA; deference to findings; potential for extra evidence)
Kerkam v. McKenzie, 862 F.2d 884 (D.C. Cir. 1989) (importance of reasoned findings in due-process decisions)
Rowley (cited above), — (—) (reiterates educational benefit standard)