## Facts

- Amanda J., a minor student receiving special education services, was evaluated by the school district in 1996.
- Two evaluations reported that Amanda displayed “autistic-like characteristics” and recommended further assessment.
- Amanda’s parents requested all assessment reports and recommendations.
- Before the initial IEP meeting, the district did not provide the parents the actual evaluation reports; after the meeting, it provided only a two-page summary that omitted concerns about autism.
- The IEP developed without the full reports did not provide services targeted to autism-related needs.
- About a year later, after the family moved to California, Amanda’s school file revealed the original evaluations referencing possible autism, indicating she went roughly a year without autism-focused services.
- The parents sought IDEA administrative relief alleging denial of a free appropriate public education (FAPE) based on the district’s nondisclosure and resulting inadequacies in services.

## Issues

1. In an IDEA case arising from a two-tier state administrative system, how should a federal court assign “due weight” when the hearing officer and review officer reach conflicting outcomes based on credibility and record evaluation?
2. Whether the district’s failure to provide parents the evaluation reports indicating possible autism and recommending further assessment was an IDEA procedural violation that denied Amanda a FAPE by impeding informed parental participation in IEP development.

## Decision

- The Ninth Circuit reversed the district court’s judgment for the district and state education agency.
- The court held that, in two-tier IDEA review systems, a federal court may give greater deference to the administrative decision that is more “thorough and careful” and better supported by the record, even if it is the hearing officer rather than the review officer.
- The court held the district violated IDEA procedures by failing to provide the parents the autism-related evaluation reports when the district learned of the suspected disability.
- The court concluded the procedural violation denied Amanda a FAPE because it seriously interfered with the parents’ ability to participate effectively and resulted in an IEP that did not address Amanda’s autism-related needs.
- The case was remanded for further proceedings consistent with the ruling, including relief aligned with the finding of a FAPE denial.

## Legal Principles

- IDEA judicial review requires courts to give “due weight” to administrative proceedings, with deference depending on the quality and care of the administrative factfinding and reasoning rather than a rigid preference for the final administrative tier.
- Parents’ rights to inspect and review education records include access to evaluations and related records needed for informed participation in IEP development.
- A procedural IDEA violation constitutes a denial of FAPE when it results in loss of educational opportunity or seriously infringes the parents’ opportunity to participate in the IEP process.
- Withholding evaluation data that identifies or strongly suggests a disability can render the IEP process defective when it prevents informed discussion of necessary assessments and services.

## Conclusion

The Ninth Circuit held that the district’s nondisclosure of evaluations suggesting autism deprived Amanda’s parents of meaningful participation in IEP formation and led to an IEP that failed to address her primary needs, constituting a denial of FAPE; it also clarified that courts may credit the more careful and well-supported administrative decision when hearing and review officers conflict.


Amanda J. v. Clark Cnty. Sch. Dist., 267 F.3d 877 (9th Cir. 2001)