K.M.

INTRODUCTION

We are presented in this case with troubling allegations of repeated failures to educate a child in government care. Appellant K.M. became a dependent of the court when she was an infant. When she was eight, the juvenile court concluded she was not adoptable and ordered respondent Los Angeles Department of Children and Family Services (DCFS) to permanently place her into foster care. Between 2017 and 2020, DCFS shuttled appellant among more than a dozen schools in nine school districts, without notifying any of them that appellant had special educational needs. She is now 20—but she reads at a first-grade level. Appellant commenced formal legal proceedings against several governmental entities by filing an administrative complaint under the Individuals with Disabilities Education Act’s administrative hearing process. Proceedings then moved to the trial court by way of a petition for administrative mandamus. Now the matter is before this court. Although the harm to K.M. is grievous, the legal issue before us is narrow: Putting aside obligations the law imposes on other governmental entities—obligations not presently before us—does DCFS’s failure to notify the schools…