District Not Required to Transport Student to Private After-School Program

A mother sought transportation for her 10-year-old son with autism from his school to a privately funded after-school program at the Northridge Recreation Center. The district offered school-to-school transportation but declined to extend it to the private program. The ALJ ruled in favor of the district, finding that IDEA only requires transportation to and from school, not to privately funded after-school programs.

What Happened

Student is a 10-year-old boy with autism who attended fifth grade at the District's Lokrantz Special Education Center during the 2011–2012 school year. He had additional medical needs that occasionally required emergency adult intervention. During that school year, the Los Angeles County Regional Center funded a private after-school program for Student at Tarzana Day Care Center, where he received 1:1 aide support to work on social skills. As an informal courtesy, the district had been dropping Student off at Tarzana Day Care after school rather than at home — but this arrangement was never written into his IEP.

In May 2012, the district held an IEP meeting and offered Student placement at Danube Elementary School for the 2012–2013 school year. The IEP included school-to-school transportation, with Student being picked up at Northridge Middle School (where his mother worked) in the morning and returned there at the end of the school day. Mother asked the district to instead transport Student after school to the Northridge Recreation Center (NRC), where she had arranged a new privately funded after-school program. The district declined, explaining that its transportation obligation ran between District campuses or to the student's home. Mother filed for due process, arguing that the refusal to transport Student to NRC denied him a FAPE.

What the ALJ Found

The ALJ ruled entirely in favor of the district, finding that Student failed to prove a denial of FAPE. Key findings included:

IDEA Only Requires School-Related Transportation: Federal regulations define transportation as travel to and from school, between schools, or in and around school buildings. Transportation to a privately funded after-school program is not required under the IDEA.
Private After-School Program Not Part of the IEP: The NRC after-school program was funded by the Regional Center, not the school district, and was never incorporated into any IEP. Because it was not an IEP service, the district had no obligation to facilitate transportation to it.
Parent Convenience Is Not a FAPE Requirement: The evidence showed that the primary reason Mother wanted the district to transport Student to NRC was because her own work schedule made it impossible for her to do so herself. Courts and hearing officers have consistently held that districts are not required to accommodate a parent's scheduling preferences or convenience.
The District's Transportation Offer Was Legally Sufficient: The district offered school-to-school transportation with Student seated near the driver to address his medical needs. This offer met the requirements of the IDEA.
Unraised Claims Were Not Considered: Mother raised additional concerns at the hearing — including about safety awareness goals and mainstreaming — that were not included in the original complaint. The ALJ declined to rule on these issues because they were not properly before the hearing.

What Was Ordered

Student's claim for relief was denied in its entirety.
The district was declared the prevailing party on the only issue heard and decided.
No compensatory services, transportation, or other remedies were ordered.

Why This Matters for Parents

Put every transportation arrangement in writing in the IEP. The informal drop-off at Tarzana Day Care worked for years but was never part of the IEP. When the placement changed, the district had no obligation to continue it. Always insist that agreed-upon transportation accommodations be written into the IEP document itself.
Understand the limits of IDEA transportation rights. The IDEA requires transportation to and from school or between schools — not to private programs, even programs that genuinely benefit your child. If your child receives services through Regional Center or another funding source, transportation to those programs is generally not the school district's responsibility.
Raise all of your concerns in your due process complaint. If you file for due process, you must include every issue you want decided. Claims raised for the first time at the hearing — like safety awareness goals or mainstreaming concerns — will not be considered unless the other party agrees. Work with an advocate or attorney to make sure your complaint is complete before filing.
Regional Center and school district services are separate systems. Services funded by the Regional Center (like a 1:1 after-school aide) are not the same as IEP services. If you want school district support for skills developed in a private program, you must specifically advocate for related goals or services to be added to the IEP.
A transportation request based on your work schedule may not succeed. Hearing officers distinguish between transportation that is educationally necessary and transportation that primarily benefits parent logistics. If you are seeking a non-standard transportation arrangement, focus your argument on your child's educational needs — not scheduling convenience.

What Happened

What the ALJ Found

The ALJ ruled entirely in favor of the district, finding that Student failed to prove a denial of FAPE. Key findings included:

IDEA Only Requires School-Related Transportation: Federal regulations define transportation as travel to and from school, between schools, or in and around school buildings. Transportation to a privately funded after-school program is not required under the IDEA.
Private After-School Program Not Part of the IEP: The NRC after-school program was funded by the Regional Center, not the school district, and was never incorporated into any IEP. Because it was not an IEP service, the district had no obligation to facilitate transportation to it.
Parent Convenience Is Not a FAPE Requirement: The evidence showed that the primary reason Mother wanted the district to transport Student to NRC was because her own work schedule made it impossible for her to do so herself. Courts and hearing officers have consistently held that districts are not required to accommodate a parent's scheduling preferences or convenience.
The District's Transportation Offer Was Legally Sufficient: The district offered school-to-school transportation with Student seated near the driver to address his medical needs. This offer met the requirements of the IDEA.
Unraised Claims Were Not Considered: Mother raised additional concerns at the hearing — including about safety awareness goals and mainstreaming — that were not included in the original complaint. The ALJ declined to rule on these issues because they were not properly before the hearing.

What Was Ordered

Student's claim for relief was denied in its entirety.
The district was declared the prevailing party on the only issue heard and decided.
No compensatory services, transportation, or other remedies were ordered.

Why This Matters for Parents

Put every transportation arrangement in writing in the IEP. The informal drop-off at Tarzana Day Care worked for years but was never part of the IEP. When the placement changed, the district had no obligation to continue it. Always insist that agreed-upon transportation accommodations be written into the IEP document itself.
Understand the limits of IDEA transportation rights. The IDEA requires transportation to and from school or between schools — not to private programs, even programs that genuinely benefit your child. If your child receives services through Regional Center or another funding source, transportation to those programs is generally not the school district's responsibility.
Raise all of your concerns in your due process complaint. If you file for due process, you must include every issue you want decided. Claims raised for the first time at the hearing — like safety awareness goals or mainstreaming concerns — will not be considered unless the other party agrees. Work with an advocate or attorney to make sure your complaint is complete before filing.
Regional Center and school district services are separate systems. Services funded by the Regional Center (like a 1:1 after-school aide) are not the same as IEP services. If you want school district support for skills developed in a private program, you must specifically advocate for related goals or services to be added to the IEP.
A transportation request based on your work schedule may not succeed. Hearing officers distinguish between transportation that is educationally necessary and transportation that primarily benefits parent logistics. If you are seeking a non-standard transportation arrangement, focus your argument on your child's educational needs — not scheduling convenience.