K.D. ex rel. C.L. v. Department of Education

Plaintiff-Appellant K.D., a minor who has been diagnosed with autism, appeals the district court’s affirmance of the Hawaii Department of Education (DOE) hearing officer’s decision that K.D.’s free and appropriate public education placement complied with the Individuals with Disabilities Education Act (IDEA), 20 *1114 U.S.C. § 1400 et seq. K.D. also claims that his tuition reimbursement request for the 2007-08 school year was timely, and that Loveland Academy (Loveland) was his “stay put” placement. We affirm the decision of the district court.

FACTUAL AND PROCEDURAL BACKGROUND

I. Statutory Framework

The IDEA ensures that “all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepare them for further education, employment, and independent living.” 20 U.S.C. § 1400 (d)(1)(A). The IDEA primarily seeks to make public education available to handicapped children who were previously excluded from any form of public education. Bd. of Educ. of Hendrick Hudson Cent. Sch. Dist. v. Rowley, 458 U.S. 176, 191-92 , 102 S.Ct. 3034 , 73 L.Ed.2d 690 (1982).…