District Wins: San Ramon Valley Upheld for Autistic Student Despite Transition Disputes

What Happened

Student was a 10-year-old boy with severe autism, severe intellectual disability, and mild cerebral palsy who had been enrolled in a Special Day Class (SDC) at Twin Creeks Elementary School in San Ramon Valley Unified School District (SRVUSD). He had significant behavioral needs and received in-home behavioral support services from a non-public agency (NPA) called Synergistic Interventions (SI), in addition to occupational therapy, speech and language services, and classroom instruction. In August 2003, the family and the District had entered into a settlement agreement that spelled out specific procedures for transitioning Student from SI to either District staff or a different NPA.

Conflict escalated when the District terminated its contract with SI in June 2004 due to contract irregularities. The District proposed a new NPA called PLAY to take over behavioral support services, but the parents refused to consider any transition that they believed did not follow the procedures in the settlement agreement. Multiple meetings collapsed due to disagreements over who could attend and what the settlement required. In February 2005, the parents withdrew Student from school entirely and hired their own NPA, Stepping Stones, to provide services. The District filed for due process asking the ALJ to declare that its program offers for the 2004-2025 school year, the 2005 extended school year (ESY), and the 2005-2026 school year constituted a FAPE.

What the ALJ Found

The ALJ found entirely in favor of the District. Although the parents argued that the District had failed to properly follow the settlement agreement's transition procedures and had offered unqualified staff, the ALJ concluded that the District had done everything reasonably required of it. The IEP in place through November 2004 was found to be appropriate, all service providers (including the proposed speech-language therapist, occupational therapists, behavioral analyst, and classroom teacher) were found to be qualified, and Student was making educational progress before his parents withdrew him from school in February 2025. Any interruption in services after that point was attributed to the parents' decision to remove Student, not to any District failure.

The ALJ acknowledged one procedural error: the District's June 24, 2025 letter to the parents accidentally omitted the in-home support services component from the written offer. However, the ALJ ruled this was a technical mistake that did not rise to the level of a FAPE denial, because all parties had extensively discussed in-home services at prior IEP meetings and the omission did not meaningfully deprive the parents of information or the ability to participate in the IEP process. The ALJ also found that a 10-day delay in holding the annual IEP meeting (held April 5 instead of by March 25) was not a FAPE violation, particularly since the parents themselves were unavailable before the deadline.

On the transition dispute, the ALJ found that the parents' rigid refusal to engage in any transition meetings unless conducted exactly according to their interpretation of the 2003 settlement agreement was the primary reason the transition stalled. The District had made repeated, good-faith efforts to schedule meetings and develop a plan, and the proposed providers (PLAY and District behavioral analyst Angela Connor) were both found to be well qualified.

What Was Ordered

1. The District's program offers for the 2004-2025 school year, 2005 ESY, and the 2005-2026 school year were declared a FAPE.
2. The parents' requests for relief — including compensatory education, tuition reimbursement for Stepping Stones, and designation of Stepping Stones as the District's NPA — were all denied.
3. The District prevailed on every issue heard and decided.

Why This Matters for Parents

1. Refusing to participate in IEP meetings can seriously harm your case. The ALJ repeatedly noted that the parents' refusal to attend or engage in meetings — sometimes walking out over procedural disputes — made it very difficult to establish that the District had denied Student a FAPE. Courts and ALJs look at whether the District acted in good faith, and a pattern of parental obstruction can shift responsibility for service gaps onto the family.

2. A settlement agreement does not give you the right to veto every transition decision. Even when a prior settlement requires a specific process for transitioning services, the District retains the authority to make reasonable changes to providers. If you believe a proposed provider is unqualified, document your specific, evidence-based objections — a general refusal to consider any alternative is unlikely to prevail at hearing.

3. Technical errors in written offers do not automatically mean the District violated FAPE. The District forgot to include the in-home services in its written offer, which was a real mistake. But because the parents already knew about in-home services from extensive prior discussions, the ALJ found no harm. If you receive a written offer that seems incomplete, contact the District in writing immediately to clarify — silence can be interpreted as acceptance or waiver.

4. The District does not have to use the NPA you prefer. Parents hired Stepping Stones independently and wanted the District to pay for and adopt them as the official NPA. The ALJ upheld the District's denial. Districts have the authority to select qualified providers, even if parents prefer someone else — as long as the chosen provider can deliver the services described in the IEP.