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When Program Closure Is Not a Change in Placement

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...
When Program Closure Is Not a Change in Placement

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2024 WL 4438472, 124 LRP 35901, aff’d, No. 24-2727, 2025 WL 649894, 125 LRP 6255 (3d Cir. Feb. 28, 2025) (unpublished), the district court ordered, and the Third Circuit affirmed, injunctive relief requiring a...
When Program Closure Is Not a Change in Placement

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 Nov. 4, 2024) (not precedential), the Minnesota Court of Appeals affirmed a state education department decision requiring corrective action after a school district...
When Program Closure Is Not a Change in Placement

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...
When Program Closure Is Not a Change in Placement

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...
When Program Closure Is Not a Change in Placement

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In Upper Darby School District v. K.W., Nos. 23-2650, 23-265, 2024 WL 3811990, 124 LRP 30821 (3d Cir. Aug. 14, 2024) (unpublished), the Third Circuit affirmed a district court’s determination that a school district denied a student a free appropriate public education...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