Yolo County Office of Education v State of California Department of Education, 2:11-cv-03224, No. 19 (E.D.Cal. Aug. 1, 2012) (2024)

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`Case 2:11-cv-03224-MCE-JFM Document 19 Filed 08/01/12 Page 2 of 15
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`BACKGROUND
`
`Plaintiff, Yolo County Office of Education (“YCOE”), brings
`suit against Defendant California Department of Education
`(“CDE”), pursuant to provisions 20 U.S.C. §§ 1415(b)(6) and
`1415(i)(2)(B) of the Individuals with Disabilities Education Act
`(“IDEA”), 20 U.S.C. §§ 1400 et seq. (Complaint (“Compl.”) ECF
`No. 2, at 1.) YCOE is aggrieved by what it views as an abuse of
`discretion by the CDE – and by failures in the CDE’s informal
`dispute resolution proceedings – in a dispute that arose between
`YCOE and a student regarding the use of American Sign Language.
`In this action, YCOE brings suit against CDE seeking a
`declaration of the rights and obligations of both parties under
`the IDEA. (Id.) Before turning to the factual allegations and
`the parties’ contentions, the Court briefly discusses the IDEA,
`its implementation in California and, of particular relevance
`here, the dispute resolution process.
`
`A.
`
`IDEA Framework, California’s Implementation and Dispute
` Resolution Process
`
`The IDEA provides that all children with disabilities
`receive a free appropriate public education (“FAPE”) through
`individualized education programs (“IEP”). Lake Washington
`School District No. 414 v. Office of Superintendent of Public
`Instruction, 634 F.3d 1065, 1066 (9th Cir. 2011) (citing
`20 U.S.C. §§ 1400(d)(1)(A)) and 1415(a)). “The IDEA conditioned
`federal funding upon state compliance with the statute’s
`‘extensive substantive and procedural requirements.’”
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`Id. (quoting Hoeft v. Tucson Unified Sch. Dist., 967 F.2d 1298,
`1300 (9th Cir. 1992). Under California law, the county office of
`education of the child’s residence is obligated “to identify
`disabled children, to assess suspected disability, to determine
`educational placements and related services through an IEP, and
`to provide needed education and related services.” S.A. ex rel.
`L.A. v. Tulare County Office of Educ., 2009 WL 30298, at *4 (E.D.
`Cal. Jan. 6, 2009) (citing Cal. Educ. Code, §§ 56300, 56302,
`56340, and 56344(b)).
`The IDEA provides a framework for dispute resolution that
`includes both a formal process and an informal one. See
`20 U.S.C. § 1415; 34 C.F.R. § 300.151. As part of this process,
`the State and local agencies must provide students with
`procedures that allow a parent or a public agency to present a
`complaint with respect to “any matter relating to the
`identification, evaluation, or educational placement of the
`child, or the provision of a free appropriate public education to
`such child.” 20 U.S.C. § 1415(b)(6)(A), see also
`§ 1415(b)(7)(A); 34 C.F.R. § 300.507(a)(1). The implementing
`provisions call for the State Education Agency to address
`failures to provide appropriate services, and “appropriate future
`provision of services for all children with disabilities.” See
`34 C.F.R. § 300.151. The regulations also provide “the public
`agency with the opportunity to respond to the complaint.”
`34 C.F.R. § 300.152. The statute provides for either a formal
`impartial due process hearing under § 1415(f) or an informal
`voluntary mediation pursuant to § 1415(e).
`///
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`The formal prong of the IDEA’s dispute resolution process is
`the due process hearing. When a party makes a complaint under
`§ 1415(b)(6), “the parents or the local educational agency
`involved in such complaint shall have an opportunity for an
`impartial due process hearing, which shall be conducted by the
`State educational agency..., as determined by State law...”
`20 U.S.C. § 1415(f)(1)(A); see also 34 C.F.R. § 300.506. In
`California, the “CDE is required to enter into an interagency
`agreement with another state agency or contract with a nonprofit
`organization to provide the independent and impartial process.”
`S.A., 2009 WL 30298 at *4 (citing Cal. Educ. Code § 56504.5).
`The due process hearing’s formal procedural features include,
`inter alia, the right to counsel, the right to present evidence,
`and the right to cross-examine witnesses. See, e.g., Pedrazza v.
`Alameda Unified Sch. Dist., 2011 WL 4507111, at *5 (N.D. Cal.
`2011) (citing 20 U.S.C. §§ 1415(f),(h); 34 C.F.R. §§ 300.511,
`300.512); R.K. v. Hayward Unified Sch. Dist., 2007 WL 4169111, at
`*3 (N.D. Cal. 2007). Any party to a due process hearing who is
`aggrieved by the State Education Agency shall “have the right to
`bring a civil action with respect to the complaint presented
`pursuant to this section, which action may be brought in any
`State court of competent jurisdiction or in a district court...”
`20 U.S.C. § 1415(i)(2)(A).
`The alternative procedural safeguard provided for by the
`IDEA is the voluntary, informal mediation Complaint Resolution
`Procedure, available pursuant to § 1415(e).
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`That provision provides that any State Education Agency or Local
`Education Agency must “ensure that procedures are established and
`implemented to allow parties to disputes involving any matter,
`including matters arising prior to the filing of a complaint
`pursuant to subsection (b)(6), to resolve such disputes through a
`voluntary mediation process.” 20 U.S.C. § 1415(e)(1). The
`mediation is “similar to an informal settlement conference.
`S.A., 2009 WL 30298 at *7. The mediation must be “conducted by a
`qualified and impartial mediator, and cannot be used “to deny or
`delay a parent’s right to a due process hearing...” 20 U.S.C.
`§ 1415(e)(2)(A). Mediation procedures are outlined for matters
`“arising prior to the filing of a due process complaint.” See
`34 U.S.C. § 300.506 (emphasis added).
`
`B.
`
`Factual and Procedural Background1
`
`On May 6, 2011, the parents of a special needs student
`enrolled in a YCOE program for the Deaf and Hard of Hearing
`submitted a request for a compliance complaint investigation
`under California’s Complaint Resolution Procedures (“CRP”) to the
`CDE alleging that YCOE failed to provide the student with
`directions for state testing in American Sign Language (“ASL”).
`(Id. at 3.)
`///
`
` Unless otherwise noted, all factual background information
`1
`is taken from the Complaint’s factual allegations. For the
`purposes of this Motion to Dismiss, the Court accepts YCOE’s
`facts as true and makes all inferences in the light most
`favorable to Plaintiff.
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`The CDE thereafter issued a Compliance Complaint Report
`(“Report”) which found YCOE out of compliance with state and
`federal law. (Id.)
`YCOE then submitted a request for reconsideration to CDE,
`essentially alleging that CDE reached the wrong conclusion.
`(Id.) In support for its contention that it had complied with
`its obligation to provide accommodations to the CDE, YCOE
`provided an affidavit, signed by the student’s classroom teacher
`affirming that she provided all required accommodations. (Id. at
`4.) Thereafter, CDE issued its Reconsideration Report, which was
`allegedly written by the same CDE employee who issued the initial
`report. (Id.) In the Reconsideration Report, CDE allegedly
`found that the student did receive accommodation during state
`testing and revised its original findings, but CDE ultimately
`reconfirmed its initial conclusion that YCOE was out of
`compliance for failing to provide the student with directions in
`ASL during state testing. (Id.) YCOE therefore asserts that the
`CDE abused its discretion in finding YCOE out of compliance
`because there was no evidentiary basis for that finding. (Id.)
`YCOE thereafter brought this lawsuit. It alleges that CDE
`abused its discretion when it found YCOE out of compliance, and
`that CDE’s decision is therefore “irrelevant, a nullity, and
`insufficient as a matter of law.” (Id.) YCOE alleges that CDE
`exceeded “the express statutory authority provided to the CDE
`under the IDEA.” (Id. at 5.) YCOE claims that CDE exceeded its
`authority by issuing its report “without any evidentiary basis.”
`(Id.)
`///
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`YCOE seeks declaratory and injunctive relief. Specifically,
`YCOE seeks a declaration as to: (1) the evidentiary standard of
`review applicable to state compliance complaint proceedings;
`(2) who bears the burden of proof to establish a violation of
`compliance complaint proceedings; (3) whether CDE acted in excess
`of its statutory authority when it issued its Reconsideration
`Report; and (4) whether YCOE is permitted to not comply with
`CDE’s order. (Id. at 5.) YCOE also seeks injunctive relief to
`prevent implementation of CDE’s order. (Id.)
`CDE moves to dismiss on the grounds that: (1) there is no
`private right of action under the IDEA against the CDE stemming
`from the CRP, therefore, this Court lacks standing to consider
`YCOE’s complaint; and (2) YCOE failed to exhaust its
`administrative remedies by pursuing the alternative formal due
`process hearing process. (ECF No. 9). 2
`///
`///
`///
`///
`///
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` Pursuant to Federal Rules of Evidence 201(b) (authorizing
`2
`judicial notice of adjudicative facts ‘capable of accurate and
`ready determination by resort to sources whose accuracy cannot be
`reasonably questioned’), CDE requests the Court take judicial
`notice of: (1) a copy of 71 Federal Register 46607 (Aug 14,
`2006); and (2) copies of sections 3000, 4650, 4664 and 4665 of
`Title 5 of the California Code of Regulations. (ECF No. 9,
`Ex. 2.) CDE’s’s requests are unopposed and are the proper
`subject of judicial notice. See, e.g., Champlaie v. BAC Home
`Loans Servicing, LP, 706 F. Supp. 2d 1029, 1040 (E.D. Cal. 2009);
`Lee v. County of Los Angeles, 250 F.3d 668, 688 (9th Cir. 2001)
`(court may take judicial notice of matters of public record).
`Accordingly, CDE’s Request for Judicial Notice, (ECF No. 9,
`Ex. 2), is granted.
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`STANDARD
`
`On a motion to dismiss for failure to state a claim under
`Rule 12(b)(6), all allegations of material fact must be accepted
`as true and construed in the light most favorable to the
`nonmoving party. Cahill v. Liberty Mut. Ins. Co., 80 F.3d 336,
`337-38 (9th Cir. 1996). Federal Rule of Civil Procedure 8(a)(2)
`requires only “a short and plain statement of the claim showing
`that the pleader is entitled to relief,” in order to “give the
`defendant fair notice of what the...claim is and the grounds upon
`which it rests.” Conley v. Gibson, 355 U.S. 41, 47, 78 S. Ct.
`99, 2 L. Ed. 2d 80 (1957). While a complaint attacked by a Rule
`12(b)(6) motion to dismiss does not need detailed factual
`allegations, a plaintiff’s obligation to provide the “grounds” of
`his “entitlement to relief” requires more than labels and
`conclusions, and a formulaic recitation of the elements of a
`cause of action will not do. Bell Atl. Corp. v. Twombly,
`2007 U.S. LEXIS 5901, 20-22 (U.S. 2007) (internal citations and
`quotations omitted). Factual allegations must be enough to raise
`a right to relief above the speculative level. Id. at 21 (citing
`5 C. Wright & A. Miller, Federal Practice and Procedure § 1216,
`pp. 235-236 (3d ed. 2004) (“The pleading must contain something
`more...than...a statement of facts that merely creates a
`suspicion [of] a legally cognizable right of action”).
`If the court grants a motion to dismiss a complaint, it must
`then decide whether to grant leave to amend.
`///
`///
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`The court should “freely give[]” leave to amend when there is no
`“undue delay, bad faith[,] dilatory motive on the part of the
`movant,...undue prejudice to the opposing party by virtue of...the
`amendment, [or] futility of the amendment....” Fed. R. Civ. P.
`15(a); Foman v. Davis, 371 U.S. 178, 182 (1962). Generally, leave
`to amend is only denied when it is clear that the deficiencies of
`the complaint cannot be cured by amendment. DeSoto v. Yellow
`Freight Sys., Inc., 957 F.2d 655, 658 (9th Cir. 1992).
`
`ANALYSIS
`
`CDE moves to dismiss on the basis that there is no private
`right of action under the IDEA for a Local Educational Authority,
`to appeal, in essence, appeal the decision of the CDE arising
`from the informal complaint resolution process. Furthermore, CDE
`contends that YCOE has not demonstrated that it exhausted its
`administrative remedies before it filed this action because YCOE
`has not alleged that it pursued the alternative formal due
`process hearing procedures, from which a private right of action
`is explicitly available.
`
`A.
`
`No Private Cause of Action For A Local Education
`Agency.
`1.
`Parties’ Contentions
`
`YCOE relies on S.A., a 2009 case from the Eastern District
`of California, for the proposition that “a private right of
`action exists in federal court to challenge the state’s CRP
`conclusions.” (Opposition (“Opp.”) ECF No. 14 at 7.)
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`In S.A., the court held that, under the IDEA, a student was
`entitled to a private right of action against the CDE for alleged
`failure to produce the student’s requested educational records.
`See S.A., 2009 WL 30298. There, during the CRP proceeding, the
`CDE had informed the student that “any further disagreement with
`the report can be appropriately addressed in a court of competent
`jurisdiction.” Id. at 8. The district court held that the “CDE
`cannot at the administrative level indicate that a court action
`is available and later before a court indicate it is not.” Id.
`YCOE argues that S.A. clearly establishes that there is a
`private right of action to challenge a CRP in federal court.
`(Opp. at 6.) YCOE contends that the only material difference
`between S.A. and the instant case is that here, the Local
`Education Agency, YCOE, and not the student, is bringing the
`action. (Opp. at 7.) YCOE suggests that if a private right of
`action exists to challenge a CRP for students and their parents,
`that avenue is available to any party aggrieved by the CRP,
`including a Local Education Agency. (Opp. at 7.)
`CDE counters that S.A. is factually distinguishable because
`in that case the State Education Agency erroneously indicated to
`the parent that there was a private cause of action, and that the
`court found that this statement created an issue that precluded
`dismissal. (Reply, ECF No. 15 at 6.)
`///
`///
`///
`///
`///
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`CDE argues further that S.A. is inapposite because while that
`case does allow a private right of action for a parent to
`challenge a CRP, the S.A. court relied on Ninth Circuit authority
`that does not persuasively support that proposition. (MTD at
`3
`13.)
`
`Finally, CDE contends that YCOE’s reliance on the Eastern
`District’s 2009 S.A. decision is misplaced because the Ninth
`Circuit’s 2011 decision in Lake Washington explicitly held that
`the IDEA does not create a private right of action for school
`boards and Local Education Agencies to contest a State’s
`compliance with the IDEA’s procedural protections. CDE contends
`that YCOE’s action is essentially an appeal from a CRP decision
`of the CDE challenging the CDE’s procedures. This, contends CDE,
`is exactly the sort of challenge prohibited by Lake Washington.
`///
`///
`///
`
` One of the Ninth Circuit cases relied on in S.A. was
`3
`Christopher S. v. Stanislaus County Office of Education, 384 F.3d
`1205 (9th Cir. 2004). In that case, three autistic students in a
`special education program pursued a state CRP to address a
`district-wide policy that provided for a shortened school day for
`autistic students. Christopher, 384 F.3d at 1206. The court
`held that the students were not required to exhaust
`administrative remedies by seeking a due process hearing before
`bringing action. Id. As Plaintiff concedes in its Opposition,
`Christopher primarily addressed the issue of exhaustion of
`administrative remedies. The instant case does not involve a
`blanket, district-wide policy directed at a group of students
`with a particular disability. The facts of that case made it
`unnecessary to pursue administrative remedies through due process
`hearings because the state was already on notice of the allegedly
`unlawful policy, and no individual student had been denied due
`process because of the across-the-board nature of the policy.
`See id. at 1210-11. Therefore, Christopher does not support the
`proposition that there is always a private right of action to
`challenge a CRP.
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`2.
`
`Analysis
`
`In 2011, the Ninth Circuit held that a school district
`lacked statutory standing to challenge a state’s compliance with
`IDEA’s procedural protections. See Lake Washington School
`District No. 414 v. Office of Superintendent of Public
`Instruction, 634 F.3d 1065 (9th Cir. 2011). In Lake Washington,
`the plaintiff school district sought to enjoin the State of
`Washington from granting continuances greater than 45 days in any
`administrative proceedings conducted pursuant to the IDEA. Id.
`at 1066. The School District believed that the continuance
`violated the IDEA’s requirement that “a decision be issued within
`45 days of the expiration of the 30-day resolution period,” and
`the State Educational Agency was thus exceeding its authority
`under the statute. Id. at 1067.
`The court found that the IDEA “establishes a private right
`of action for disabled children and their parents. It creates no
`private right of action for school boards or Other Local
`Education Agencies apart from contesting issues raised in the
`complaint filed by the parents on behalf of their child.” Id. at
`1068. The Lake Washington court found support for this
`proposition in the opinions of a number of decisions from other
`circuits. Id. (Citing, e.g., Traverse Bay Area Intermediate Sch.
`Dist. v. Mich. Dep’t of Educ., 615 F.3d 622, 631 (6th Cir. 2010)
`(“[T]he IDEA does not provide School Districts with an express or
`implied right to compel State Defendant’s compliance with
`§ 1415(b)’s procedural safeguards absent an underlying claim that
`directly involves a disabled child’s IEP.”)).
`12
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`The Lake Washington court agreed with the Traverse court that the
`right to sue provided by the IDEA was “designed to benefit
`disabled children and their parents.” Id. at 1069.
`Contrary to YCOE’s claims, S.A. does not apply here because
`Lake Washington makes clear that while parents and children may
`have a private right of action to challenge the IDEA’s procedural
`protections, this right does not extend to local education
`authorities such as YCOE to litigate questions other than those
`raised in the complaint filed by the parents of the disabled
`child. Lake Washington, 634 F.3d at 1068-69. Here, YCOE is a
`Local Education Agency and is not contesting issues raised in the
`parent’s complaint, but instead is challenging the conduct of
`CDE, the State Education Agency, and, more generally, CDE’s CRP
`procedures. This is exactly the type of challenge that the Ninth
`Circuit found was prohibited in Lake Washington. Id. Therefore,
`the Court concludes that YCOE lacks standing to bring this claim
`and would grant CDE’s motion to dismiss on this basis alone.
`
`B.
`
`YCOE’s Remedy Under the IDEA Does Not Lie in
`Challenging CDE’s Conduct in Federal Court, But in
`Resolving the Underlying Complaint in a Due Process
`Hearing.
`
`However, CDE also contends that the case should be dismissed
`because by foregoing the formal due process hearing procedures,
`and instead filing this action, YCOE has failed to exhaust
`administrative remedies, as required by the IDEA, before bringing
`suit. CDE argues that YCOE’s claims are brought under the IDEA,
`and that under the statute, federal courts have no jurisdiction
`until there is a final administrative decision. (MTD at 14.)
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`YCOE responds that the due process hearing is not the appropriate
`venue for its case, and that without the ability to bring this
`suit, it would be without remedy. (Opp. at 10.)
`A plaintiff alleging futility or inadequacy of IDEA
`procedures bears the burden of proof. See Doe v. Arizona Dep’t
`of Educ., 111 F.3d 678, 681 (9th Cir. 1997). In addition, the
`plaintiff bears the burden of proving that exhaustion of the
`IDEA’s procedures would be futile or inadequate. See Robb v.
`Bethel Sch. Dist. 403, 308 F.3d 1047, 1050 n.2 (9th Cir. 2002);
`Hoeft v. Tucson Unified School Dist., 967 F.2d 1298, 1303-04
`(9th Cir. 1992). The exhaustion doctrine embodies the concept
`that “agencies, not the courts, ought to have primary
`responsibility for the programs that Congress has charged them to
`administer.” McCarthy v. Madigan, 503 U.S. 140, 145 (1992).
`Here, YCOE’s argument that the formal due process procedures
`are unavailable to raise its claims regarding CDE’s CRP process
`are unpersuasive. YCOE has not met its burden in demonstrating
`that it could not have raised its claims in the due process
`procedure, or that to do so would be futile.
`The Court therefore concludes that, even if YCOE had
`standing to pursue its claims, it still had not met its burden of
`demonstrating why it should be relieved of its obligation to
`exhaust its administrative remedies.
`///
`///
`///
`///
`///
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`Case 2:11-cv-03224-MCE-JFM Document 19 Filed 08/01/12 Page 15 of 15
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`CONCLUSION
`
`As a matter of law, and for the reasons set forth above,
`CDE’s Motion to Dismiss (ECF No. 7) is GRANTED without leave to
`amend. The Clerk of the Court is directed to close this case.
`IT IS SO ORDERED.
`Dated: July 31, 2012
`
`_____________________________
`MORRISON C. ENGLAND, JR.
`UNITED STATES DISTRICT JUDGE
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