M. M. v. Lafayette School District

This case began as a dispute over the results of CM’s special education evaluation under the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seq. (“IDEA”), but now has a convoluted procedural history, including three separate district court lawsuits and two administrative complaints. Many of these issues are outside of the narrow scope of this appeal, however, and will not be addressed in this opinion.

This appeal is limited to two distinct issues. First, the Administrative Law Judge (“ALJ”) dismissed several of CM’s claims against Lafayette School District and the Lafayette Board of Education (collectively, “Lafayette”) prior to holding a due process hearing because the claims alleged conduct outside the IDEA’S two-year statute of limitations. CM’s parents, MM and EM (collectively “MM”), sought review in the district court, which held that MM was not an “aggrieved party” under the IDEA because the ALJ had not yet held a due process hearing or issued a final ruling on MM’s complaint. Second, the district court dismissed MM’s separate claims against the California Department of Education (“CDE”), in which MM alleged that the CDE had failed to comply with…