## Facts

- Joshua A. was a student with autism enrolled in the Rocklin Unified School District (Rocklin).
- For the 2006–2007 school year, Rocklin developed an Individualized Education Program (IEP) for Joshua under the Individuals with Disabilities Education Act (IDEA).
- Joshua (through his parent/guardian) filed an IDEA due process challenge alleging Rocklin failed to provide a free appropriate public education (FAPE) for that school year.
- After hearing evidence, an administrative law judge (ALJ) issued a detailed, 22-page decision finding Rocklin provided FAPE and that the IEP was valid under IDEA because it:
  - was tailored to Joshua’s unique needs,
  - was supervised and delivered by qualified personnel, and
  - was based on accepted principles in the field of autism education.
- The ALJ’s findings matched the testimony of multiple witnesses who observed Joshua in the classroom and stated Rocklin’s program matched best practices in autism education.
- Joshua sought judicial review in federal district court, arguing the ALJ’s decision did not properly require that the IEP provide a “meaningful benefit” under IDEA.
- The district court affirmed the ALJ’s decision, and Joshua appealed to the Ninth Circuit.

## Issues

1. Whether the ALJ and district court applied the proper IDEA standard in assessing whether Rocklin’s 2006–2007 IEP provided FAPE, including whether the IEP was required to provide a “meaningful” educational benefit.
2. Whether the record supported the ALJ’s determination that Rocklin’s IEP—tailored to Joshua’s needs and implemented by qualified staff using accepted autism-education principles—satisfied IDEA’s FAPE requirement despite parental disagreement with the district’s program.

## Decision

- The Ninth Circuit affirmed the district court’s judgment upholding the ALJ’s decision.
- The court upheld the conclusion that Rocklin’s 2006–2007 IEP provided FAPE under IDEA.
- The court rejected Joshua’s argument that the ALJ’s decision failed to apply the required “meaningful benefit” standard.
- The court relied on the ALJ’s detailed findings and the testimony of classroom observers supporting the educational soundness of Rocklin’s program.

## Legal Principles

- An IEP satisfies IDEA’s substantive FAPE requirement if it is reasonably calculated to provide educational benefit in light of the child’s individual needs; IDEA does not require a district to provide the best possible program.
- In reviewing an IDEA due process decision, federal courts give due weight to supported administrative findings, particularly where the ALJ issued a detailed decision tied to the record.
- A parent’s disagreement with a district’s educational approach does not, by itself, establish a denial of FAPE when the IEP is supported by evidence that it is appropriately designed and implemented.

## Conclusion

The Ninth Circuit affirmed the judgment for Rocklin Unified School District, holding that the ALJ and district court correctly upheld Rocklin’s 2006–2007 IEP for Joshua A. as providing FAPE under IDEA, based on detailed administrative findings and record support that the program was individualized, competently implemented, and consistent with accepted autism-education principles.


Joshua A. v. Rocklin Unified School District, 319 Fed. Appx. 692 (2009)