S.L. Ex Rel. Loof v. Upland Unified School District, 747 F.3d 1155

S.L. is a minor with an intellectual disability who attended district schools and later private OLA.
Parents withdrew S.L. from public school and placed her at OLA, with private aides assisting.
June 21, 2007 settlement required districts to reimburse $18,000 and provide certain services for 2002–2006.
Disputes over a proposed 2007 assessment plan, timing, length, and attendance at an assessment meeting.
In December 2007, S.L. filed a new due process complaint alleging denial of a FAPE and failure to assess.
ALJ ruled OLA not appropriate but ordered partial reimbursement for 2007/2008; district court affirmed the partial denial; appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appropriateness of OLA placement	S.L. entitled to reimbursement because OLA provided appropriate instruction.	OLA did not provide sufficiently individualized benefit.	OLA appropriate; tuition reimbursed; S.L. entitled to related costs.
Transportation reimbursement for OLA	Transportation is a related service necessary for benefiting from education.	Transportation reimbursement not clearly required.	Transportation reimbursement awarded.
Private aides reimbursement	Aides were essential; full claimed amount should be reimbursed.	Evidence insufficient for full amount; only proven portion reimbursable.	Partial reimbursement approved; amount $6,999.25; remainder denied.
Attorney's fees appeal timeliness	Notice of judgment timing should permit appeal for fees.	Appeal was timely per Rule 4 and 58; final disposition occurred earlier.	Appeal of fees untimely; no jurisdiction.

C.B. v. Garden Grove Unified Sch. Dist., 635 F.3d 1155 (9th Cir. 2011) (de novo placement appropriateness with deference to ALJ findings)
Union Sch. Dist. v. Smith, 15 F.3d 1519 (9th Cir. 1994) (transportation and related services under IDEA)
Frank G. v. Bd. of Educ., 459 F.3d 356 (2d Cir. 2006) (appropriate private placement includes services necessary to benefit from instruction)