## Facts

- N.F. was diagnosed with severe autism and related conditions.
- For the 2002–2003 school year, the Ramapo Central School District (Ramapo) developed an individualized education program (IEP) for N.F.
- Under the IEP, N.F. attended Ramapo’s special preschool placement at Prime Time for Kids (Prime).
- At Prime, N.F. received full-day applied behavior analysis (ABA) therapy.
- The IEP did not include additional ABA therapy to be provided in the home.
- N.F.’s parents believed the IEP was deficient because it did not provide for at-home ABA therapy.
- The parents requested an IDEA due-process hearing, arguing the IEP failed to provide a free appropriate public education (FAPE).
- The hearing officer concluded that at-home ABA therapy was not required for N.F. to receive a FAPE and that Ramapo met its obligations under the IDEA.
- A state review officer (SRO) affirmed the hearing officer’s decision.
- The parents filed an action in federal district court challenging the SRO decision; both sides moved for summary judgment.
- During oral argument, the district court focused on whether N.F. had made meaningful progress at Prime under the IEP.
- The district court found evidence that N.F. had not made meaningful progress, concluded N.F. was denied a FAPE, and granted summary judgment to the parents.
- Ramapo appealed to the U.S. Court of Appeals for the Second Circuit.

## Issues

1. In reviewing an IDEA administrative decision, must a court evaluate an IEP based on the information available when it was created (rather than later evidence of the child’s progress or lack of progress)?
2. Did the district court fail to give the required due weight to the hearing officer’s and SRO’s determinations that the IEP provided a FAPE without at-home ABA?
3. Under the proper standard of review, did Ramapo’s 2002–2003 IEP provide N.F. a FAPE even though it omitted at-home ABA therapy?

## Decision

- The Second Circuit vacated the district court’s grant of summary judgment for N.F.’s parents.
- The court held that an IEP’s adequacy is assessed based on whether it was reasonably calculated to provide educational benefit at the time it was developed, not by using after-the-fact evidence as the main basis to invalidate the plan.
- The court ruled that, in IDEA cases, federal courts must give due weight to the administrative findings of the hearing officer and SRO and may not replace those determinations with the court’s own educational policy views.
- The case was remanded for the district court to apply the proper framework to the parents’ challenge to the IEP and to the administrative determinations sustaining it.

## Legal Principles

- Under the IDEA, a school district satisfies FAPE when the IEP is reasonably calculated, at the time it is written, to enable the child to receive educational benefit.
- Judicial review of IDEA administrative decisions is independent but limited; courts must give due weight to state administrative findings, especially where the SRO has reviewed the record and affirmed the hearing officer.
- A court should not treat later progress (or later lack of progress) as the controlling measure of whether the IEP was valid when made; the legal question is the plan’s adequacy as written and supported by the record available to the school district at that time.
- Summary judgment in IDEA cases functions as a review of the administrative record (and any properly admitted additional evidence), guided by the statutory standard and the required level of deference to state administrative decisionmakers.

## Conclusion

D.F. v. Ramapo Central School addresses how courts should review an IEP under the IDEA when parents claim the plan denied FAPE because it omitted a service such as at-home ABA therapy. The Second Circuit vacated the district court’s ruling for the parents because the district court’s analysis relied heavily on N.F.’s later progress and did not apply the proper, time-of-development focus or the required deference to the hearing officer and SRO; the case was remanded for reconsideration under the correct legal framework.


D.F. v. Ramapo Central School, 430 F.3d 595 (2005)