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Concern Alone Does Not Necessarily Trigger the IDEA Limitations Clock

Concern Alone Does Not Necessarily Trigger the IDEA Limitations Clock

Feb 9, 2026 | by Special Education Solutions

In Peter G. v. Derry Township School District, No. 1:23-CV-00043, 2025 WL 270057, 125 LRP 2346 (M.D. Pa. Jan. 22, 2025), the district court addressed the application of the statute of limitations for due process hearing requests under the Individuals with Disabilities...
Concern Alone Does Not Necessarily Trigger the IDEA Limitations Clock

IDEA Does Not Require Morning, Home Aides

Feb 9, 2026 | by Special Education Solutions

In S.M. v. Freehold Regional High School District Board of Education, No. 24-1299, 2025 WL 1565359, 125 LRP 16316 (3d Cir. June 3, 2025) (unpublished), the Third Circuit affirmed administrative and district court decisions rejecting a compensatory education claim...
Concern Alone Does Not Necessarily Trigger the IDEA Limitations Clock

Class Size Disputes Sent to New York’s Highest Court

Feb 9, 2026 | by Special Education Solutions

In Cruz v. Banks, 134 F.4th 687, 125 LRP 12165 (2d Cir. Apr. 15, 2025), certified question accepted, No. 64, 2025 WL 1439661 (N.Y. May 20, 2025), the Second Circuit addressed whether an individualized education program (IEP) offering a 12:1:4 classroom satisfied the...
Concern Alone Does Not Necessarily Trigger the IDEA Limitations Clock

When Accommodations Mask, Rather Than Remediate, Disability

Feb 9, 2026 | by Special Education Solutions

In William A. v. Clarksville-Montgomery County School System, 127 F.4th 656, 125 LRP 3627 (6th Cir. Feb. 3, 2025), the Sixth Circuit affirmed a determination that a school district denied a student a free appropriate public education (FAPE) under the Individuals with...
Concern Alone Does Not Necessarily Trigger the IDEA Limitations Clock

When Program Closure Is Not a Change in Placement

Feb 9, 2026 | by Special Education Solutions

In A.M-G. v. Salem Keizer Public Schools, Nos. 6:24-cv-01517-MC, 6:24-cv-01575-MK, 2024 WL 4867060, 124 LRP 40061 (D. Or. Nov. 22, 2024), the district court denied motions for temporary restraining orders and preliminary injunctions seeking to require a school...
Concern Alone Does Not Necessarily Trigger the IDEA Limitations Clock

Residential Placement Ordered Where Day Programs Failed

Feb 9, 2026 | by Special Education Solutions

In S.M. v. Chichester School District, No. 2:21-cv-04266, 2024 WL 4438472, 124 LRP 35901, aff’d, No. 24-2727, 2025 WL 649894, 125 LRP 6255 (3d Cir. Feb. 28, 2025) (unpublished), the district court ordered, and the Third Circuit affirmed, injunctive relief requiring a...
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