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No Two Ways About It: Ninth Circuit Clarifies When Two Year Statute of Limitations for Special Education Claims Begins

In J.R. v. Ventura Unified School District (9th Cir. 2026) 173 F.4th 1039, the Ninth Circuit Court of Appeals held that a lawsuit brought by parents against a school district under the Individuals with Disabilities Education Act (IDEA) was untimely as to educational services their child received before 2019, clarifying the statute of limitations period and related tolling doctrine, and re

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Ask and You Shall Receive: Ninth Circuit Clarifies IEP Request Formalities Do Not Limit FAPE Rights

In L.B. v. San Diego Unified School District (9th Cir. 2026) 168 F.4th 1150, the Ninth Circuit Court of Appeals held that both the District Court and the Office of Administrative Hearings (OAH) erred in holding that a school district was not required to offer a free appropriate public education (FAPE) to a parentally-placed private school (PPPS) child if the parents requested an “IE

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