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Categorical Placement Policies Are Suspect Under IDEA’s Individualization Requirement

Categorical Placement Policies Are Suspect Under IDEA’s Individualization Requirement

Feb 9, 2026 | by Special Education Solutions

In Jacobs v. Salt Lake City School District, No. 23-4058, 2025 WL 2858650, — F.4th —, 125 LRP 29753 (10th Cir. Oct. 9, 2025), the Tenth Circuit reversed dismissal of claims alleging that a school district violated the Individuals with Disabilities...
Categorical Placement Policies Are Suspect Under IDEA’s Individualization Requirement

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G.L. v. Verona Borough Board of Education, No. 2:23-cv-00938, 2024 WL 3549060, 124 LRP 28443 (D.N.J. July 26, 2024) (unpublished), the district court addressed disputes concerning the appropriate placement of a young student with multiple disabilities and, more...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

Clearly Defined Services Are Essential to Support Meaningful Progress

Feb 7, 2026 | by Special Education Solutions

In Los Angeles Unified School District v. A.O., 92 F.4th 1159, 124 LRP 5221 (9th Cir. Feb. 15, 2024), the Ninth Circuit considered how specific an individualized education program (IEP) must be, what constitutes a free appropriate public education (FAPE) for a young...
Categorical Placement Policies Are Suspect Under IDEA’s Individualization Requirement

FAPE Without Grade-Level Standards? The Second Circuit Says Yes

Feb 7, 2026 | by Special Education Solutions

The Second Circuit reaffirmed that an individualized education program (IEP) may satisfy both the free appropriate public education (FAPE) and least restrictive environment (LRE) requirements—even when it does not align with general education standards—where the...
Categorical Placement Policies Are Suspect Under IDEA’s Individualization Requirement

When Consensus Exists, Methodology Belongs in the IEP

Feb 7, 2026 | by Special Education Solutions

In E.E. v. Norris School District, No. 1:20‑CV‑1291‑AWI‑CDB, 2023 WL 3124618, 83 IDELR 68 (E.D. Cal. Apr. 27, 2023), the court addressed a dispute concerning the content of an individualized education program (IEP) for a student with autism spectrum disorder. The...
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