Lake Washington School District No. 414 v. Office of Superintendent of Public Instruction

Shakespeare warned us to “defer no time, delays have dangerous ends.” Perhaps Lake Washington School District no. 414 (“School District”) took the Bard’s advice a bit too seriously. When a state administrative law judge granted a short continuance, the School District immediately filed this action seeking to enjoin the State of Washington from granting continuances greater than 45 days in any administrative proceedings conducted pursuant to the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq.

The district court held that the School District lacked standing and dismissed the complaint with prejudice. We affirm.

I

The IDEA assures that all children with disabilities receive a “free appropriate public education” (“FAPE”) through individualized education programs (“IEP”). See L.M. v. Capistrano Unified Sch. Dist., 556 F.3d 900, 909 (9th Cir.2009) (citing 20 U.S.C. § 1400 (d)(1)(A)). Congress conditioned federal funding upon state compliance with the statute’s “extensive substantive and procedural requirements.” Hoeft v. Tucson Unified Sch. Dist., 967 F.2d 1298 , 1300 (9th Cir.1992). The IDEA’S “core” is the “cooperative process that it…