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Asynchronous Learning Triggered IDEA Notice Obligations

Asynchronous Learning Triggered IDEA Notice Obligations

Feb 9, 2026 | by Special Education Solutions

In In re Complaint Decision File 24-043C, No. A24-0229, 2024 WL 4664194, 124 LRP 38498 (Minn. Ct. App. Nov. 4, 2024) (not precedential), the Minnesota Court of Appeals affirmed a state education department decision requiring corrective action after a school district...
Asynchronous Learning Triggered IDEA Notice Obligations

Extended Eligibility Is Extraordinary Relief

Feb 9, 2026 | by Special Education Solutions

In Perez v. Banks, No. 1:23-CV-02966, 2024 WL 4307934, 124 LRP 28851 (S.D.N.Y. Sept. 26, 2024), aff’d, 125 LRP 22327 (2d Cir. July 31, 2025), the district court addressed whether extended eligibility under the Individuals with Disabilities Education Act (IDEA) was an...
Asynchronous Learning Triggered IDEA Notice Obligations

IDEA Exhaustion Required, but Not for Every Claim

Feb 9, 2026 | by Special Education Solutions

In Hawai‘i Disability Center v. Kishimoto, 122 F.4th 353, 124 LRP 40099 (9th Cir. Nov. 26, 2024), the Ninth Circuit addressed whether a federally funded protection and advocacy agency was required to exhaust administrative remedies under the Individuals with...
Asynchronous Learning Triggered IDEA Notice Obligations

Unaddressed Behavioral Needs Can Drive FAPE Denials

Feb 9, 2026 | by Special Education Solutions

In Upper Darby School District v. K.W., Nos. 23-2650, 23-265, 2024 WL 3811990, 124 LRP 30821 (3d Cir. Aug. 14, 2024) (unpublished), the Third Circuit affirmed a district court’s determination that a school district denied a student a free appropriate public education...
Asynchronous Learning Triggered IDEA Notice Obligations

Direct Payment or Reimbursement Requires a Developed Record

Feb 9, 2026 | by Special Education Solutions

In Moonsammy v. Banks, No. 23 Civ. 10491 (PAE), 2024 WL 4277521, 124 LRP 35077 (S.D.N.Y. Sept. 23, 2024), the district court reviewed an administrative decision that found a denial of a free appropriate public education (FAPE) under the Individuals with Disabilities...
Asynchronous Learning Triggered IDEA Notice Obligations

Surreptitious Audio Recordings May Be Admissible

Feb 9, 2026 | by Special Education Solutions

In G.L. v. Verona Borough Board of Education, No. 2:23-cv-00938, 2024 WL 3549060, 124 LRP 28443 (D.N.J. July 26, 2024) (unpublished), the district court addressed disputes concerning the appropriate placement of a young student with multiple disabilities and, more...
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