## Facts

- C.A., a Massachusetts public-school student with disabilities (including Asperger’s Syndrome, ADHD, bipolar disorder, and anxiety disorder), received special education services from the Dracut School Committee.
- The dispute concerned whether Dracut provided adequate transition assessments and transition services in C.A.’s high-school IEPs, particularly after age 16.
- A BSEA Hearing Officer found Dracut denied C.A. a FAPE by providing inadequate transition planning and services designed to prepare him for postsecondary education, employment, and independent living.
- The BSEA ordered Dracut to issue C.A. a high school diploma and provide compensatory services by extending eligibility for special education for two years beyond graduation.
- In a later compliance ruling, the Hearing Officer found Dracut did not comply with an order to hire and pay two of C.A.’s experts as consultants because Dracut offered unreasonable rates.
- Dracut sought judicial review in federal district court under the IDEA; the parent and student counterclaimed, and both sides moved for summary judgment.

## Issues

1. Whether Dracut denied C.A. a FAPE under the IDEA by failing to provide adequate age-appropriate transition assessments and sufficiently individualized transition services in high school.
2. Whether, and to what extent, the BSEA had authority to award compensatory education structured as extended eligibility beyond graduation.
3. Whether the BSEA could require Dracut to retain specific private experts as consultants and effectively control compensation terms.
4. What level of deference the district court owed to the BSEA under the IDEA’s modified de novo review with “due weight.”

## Decision

- The court affirmed the BSEA’s central determination that Dracut denied C.A. a FAPE by failing to provide adequate transition services.
- The court applied modified de novo review, giving due weight to the Hearing Officer’s education-specific factfinding.
- The court allowed compensatory relief in principle but modified aspects of the remedy and remanded for development of a more precise, individualized compensatory plan consistent with statutory limits.
- The court declined to fully uphold the BSEA’s approach to mandating retention of particular experts and compensation terms, and remanded for a more tailored remedy.
- The court allowed in part and denied in part each side’s summary-judgment motion, and remanded to the administrative forum for further proceedings consistent with the opinion.

## Legal Principles

- Under the IDEA, a FAPE must be designed to meet the child’s unique needs and prepare the child for further education, employment, and independent living.
- For students age 16 and older, an IEP must include measurable postsecondary goals based on age-appropriate transition assessments and must specify transition services (including courses of study) needed to assist the student in reaching those goals.
- A failure to provide adequate transition assessments and individualized transition services may constitute a substantive denial of FAPE.
- Judicial review of an IDEA administrative decision is “modified de novo”: the court independently assesses the record by a preponderance of the evidence while giving due weight to administrative expertise.
- Compensatory education is an equitable remedy available for a denial of FAPE, but it must be supported by the record and tailored in scope and structure to the violation and statutory framework.

## Conclusion

The district court upheld the finding that Dracut’s deficient transition assessment and planning denied C.A. a FAPE, but it required the compensatory remedy—both the post-graduation services structure and the expert-consultant component—to be recalibrated through remand to ensure the relief was appropriately individualized and within the IDEA’s remedial limits.


Dracut Sch. Comm. v. Bureau of Special Educ. Appeals of the Mass. Dep’t of Elementary & Secondary Educ., 737 F. Supp. 2d 35 (D. Mass. 2010)