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R. v. Ventura Unified School District - IDEA Statute of Limitations

The Ninth Circuit reversed the district court's judgment in this IDEA case, holding that claims for educational services received before 2019 were time-barred. The court held that the IDEA's two-year limitations period under 20 U.S.C. § 1415(f)(3)(C) begins when parents know or should know both the school district's failure to assess and diagnose their child and that the child is being denied FAPE. The panel also vacated the remedial order establishing an educational trust and the order granting a motion to enforce the judgment, remanding for further proceedings as to attorneys' fees.

J.R. v. Ventura Unified School District - IDEA Two-Year Limitations Period Ruling

The Ninth Circuit reversed the Central District of California's judgment and held that parents' IDEA lawsuit was untimely as to educational services their child received before 2019. The panel established that the IDEA's two-year statute of limitations begins when parents know or should know (1) the school's failure to assess and diagnose, and (2) that their child is being denied FAPE. The court rejected exceptions for school district misrepresentations and withheld information, finding the parents' claims predating the limitations period time-barred. The panel reversed the judgment awarding benefits for 2012-2019, vacated the educational trust order, and remanded for attorneys' fees proceedings.