Ms. S., for Herself and on Behalf of Her Daughter G. v. Vashon Island School District Office of Superintendent of Public Instruction

Ms. S, a mother committed to the education of her disabled daughter, G, brought suit against the Vashon Island School District (“VISD”) alleging that the VISD had committed procedural and substantive violations of the Individuals with Disabilities in Education Act (“IDEA”), 20 U.S.C. §§ 1400 (et seq.). Ms. S alleges that the VISD violated the IDEA by proposing a temporary individualized educational placement (“IEP”) for G that placed G in a special education classroom, segregated from the general student population. The VISD argues that the temporary placement was appropriate until the VISD had the opportunity to assess and evaluate more fully G’s needs and abilities. The district court granted summary judgment to the VISD, holding that the VISD’s proposed temporary IEP met the substantive requirements of the IDEA because it was the closest approximation to G’s last educational placement, and that any deficiencies in VISD’s procedural compliance with the IDEA were “minor and technical.” We affirm, concluding that the VISD’s efforts to serve G’s educational interests complied with the substantive and procedural requirements of the IDEA and satisfied the VISD’s obligation to provide…