M.M. v. Lafayette School District

In challenging an administrative proceeding under 20 U.S.C. § 1400 et seq ., the Individuals with Disabilities Education Act, a party may not seek review in district court until the ALJ makes a final decision as to all claims.

M.M., the parents of E.M., filed a lawsuit against the Lafayette School District (“LSD”), the Lafayette Board of Education (“LBE”), and the California Department of Education (“CDE”), challenging the administrative law judge’s (“ALJ”) dismissal of M.M.’s claims under 20 U.S.C. § 1400 et seq., the Individuals with Disabilities Education Act (“IDEA”), and alleging a failure by CDE to oversee the administrative hearing process properly. The ALJ dismissed the claims because they fell outside the statute of limitations set forth in the IDEA. The district court dismissed M.M.’s claims against LSD without prejudice, finding that M.M. was not an “aggrieved party” since the administrative proceedings were still ongoing. The district court also dismissed M.M.’s claims against CDE with prejudice, concluding that CDE lacked oversight authority over individual officers in the administrative hearing process. The Ninth Circuit agreed with the district court’s finding that “20 U.S.C. § 1415(i) does not allow immediate judicial review of pre-hearing rulings and decisions made by an ALJ in an IDEA case.” To bring suit, a party must be “aggrieved by the findings and decisions made by the ALJ” at the conclusion of the proceeding. The Ninth Circuit also found that because the CDE has no authority or responsibility to supervise administrative proceedings under the IDEA, the district court properly dismissed M.M.’s failure to oversee claims against CDE. AFFIRMED.