Mangum Ex Rel. I.M. v. Renton School District 403

MEMORANDUM

Gary and Elizabeth Mangum, parents of I.M., a home-schooled student, appeal pro se the district court’s judgment in their action under the Individuals with Disabilities Education Act, 20 U.S.C. §§ 1400-82 (“IDEA”); Section 504 of the Rehabilitation Act, 29 U.S.C. § 794 (a), and Title II of the Americans with Disabilities Act (“ADA”) and its implementing regulations, 42 U.S.C. § 12132 , 28 C.F.R. § 35.103 (a); and the Washington Law Against Discrimination (“WLAD”), RCW § 49.60.215(1), in favor of Renton School District # 403 (“the District”). Because the parties are familiar with the facts, we do not review them here.

The district court properly granted summary judgment to the District on the Man-gums’ IDEA claims relating to' actions pri- or to April 2008 because the Mangums failed to challenge the relevant actions of the District within the two-year period required by the statute, and none of the exceptions to the two-year requirement are applicable here. 20 U.S.C. § 1415 (f)(3)(C)-(D). The district court properly held that the Mangums had no valid claims based on conduct between April 2008 and the administrative law judge’s (“ALJ’s”) June 2010 ruling because the…