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Brent C. v. San Diego Unified Sch. Dist.
No. 96-1377-IEG (S.D. Cal. Aug. 11, 1996) ; Clearinghouse Number: 51593
Description
Students with Disabilities Are Entitled to Transportation Services to Day Treatment Program During the Summer when Regular School Is Not in Session
Abstract
The district court has granted plaintiff students’ motion for
a temporary restraining order in this action challenging defendant
school district’s decision to terminate transportation
services to plaintiffs following the end of the school year.
Plaintiffs, students who have been identified as severely
emotionally disturbed, had been receiving transportation from their
homes to their educational programs, based in a community day
treatment facility, where they received both academic and
psychotherapy services. Although the school year ended in July,
plaintiffs’ day treatment programs were scheduled to continue
through to the start of the new semester. Without notice to
plaintiffs’ families, defendant terminated all transportation
services to plaintiffs for the remainder of the summer on the
ground that it was not defendant’s responsibility to provide
such transportation when defendant’s schools were not in
session. Plaintiffs initially sought administrative review of
defendant’s decision. However, the hearing officer denied
plaintiffs’ motion for an emergency "stay put"
order pursuant to the Individuals with Disabilities Education Act,
20 U.S.C. §§ 1400 et seq., holding that (1) the mental
health services plaintiffs received at day treatment were not
additional services covered by the children’s Individualized
Education Plans, and (2) defendant had no responsibility to
continue those services pending the administrative hearing.
Plaintiffs then filed the instant action. Granting
plaintiffs’ motion for a temporary restraining order, the
court held that defendant’s refusal to provide plaintiffs
transportation to their day treatment program exposed them to
irreparable harm by causing severe regression in their progress and
to the possibility of being discharged from the program due to
absence. Taking judicial notice of Walnut Valley Unified Sch.
Dist., No. 465-95, in which the Special Education Hearing Office
held that a school district is responsible for transportation of
students to day treatment programs to receive mental health
services during the summer, the court held that plaintiffs were
likely to succeed on the merits at their upcoming due process
hearing. Counsel notes that defendant subsequently agreed to
provide to all special education students transportation to the
students’ related treatment programs when school is not in
session.
