C.B. Ex Rel. Baquerizo v. Garden Grove Unified School District

After the Garden Grove Unified School District (“District”) repeatedly failed to provide a free appropriate public education to student C.B., as required by the Individuals with Disabilities in Education Act (“IDEA”), 20 U.S.C. §§ 1400-1482 , his aunt and guardian (“Guardian”) enrolled C.B. in a non-public program, the Reading and Language Center (“Center”). Guardian sought reimbursement for the full cost of sending C.B. to the Center. An administrative law judge (“ALJ”) found that C.B. received significant educational benefits from attending the Center. But, because the ALJ found that the Center did not meet all of C.B.’s educational needs, he awarded only half of the reimbursement sought. Guardian filed this action, as a result of which the district court awarded full reimbursement. We affirm, because the statute does not require that a private school placement provide all services that a disabled student needs in order to permit full reimbursement.

BACKGROUND

C.B. is eligible for special education and related services because of autism and attention deficit disorder. In 2006, the District concluded that he has “unique needs in reading comprehension, math, math…