LAUSD Not Required to Provide iPad After 60-Day Touchscreen Trial Showed Limited Benefit
A parent requested that Los Angeles Unified School District provide her son, a seven-year-old with orthopedic impairment and significant physical disabilities, with an iPad based on an independent assistive technology assessment. The district instead conducted a 60-day trial of a desktop touchscreen computer, which Student struggled to use effectively at school, and concluded touchscreen technology was not appropriate at that time. The ALJ ruled in favor of the district, finding that its methodology decisions were reasonable and did not deny Student a free appropriate public education.
What Happened
Student was a seven-year-old boy with orthopedic impairment, born with hydrocephalus, multiple brain deformities, mitochondrial disease, and seizure disorder. These conditions severely affected his fine and gross motor skills, making it impossible for him to write or color independently with a pencil or crayon. In 2011, an independent assistive technology (AT) assessment conducted by the Assistive Technology Exchange Center (ATEC) — funded through the regional center, not the district — recommended that Student receive an iPad or touchscreen laptop as the most direct and efficient way for him to access writing and computer software. Parent purchased an iPad at home, which Student used daily and appeared to benefit from. Parent then requested that the district provide an iPad at school.
The district considered the ATEC report but did not simply adopt its recommendation. Instead, the IEP team proposed a 60-day trial of a desktop touchscreen computer in the classroom. During the trial, staff observed that Student frequently "punched" the screen with too much force, tantrummed when required to use it, lost interest after about 10 minutes, and deliberately got answers wrong to hear the error buzzer. Teachers and therapists found that Student made more academic progress using hands-on manipulatives — like shaping letters in Playdoh or shaving cream — than using the touchscreen. After the trial, the district concluded that touchscreen technology was not appropriate for Student at that time, and continued providing OT services to address his fine motor needs. Parent filed for due process, arguing the district denied Student a FAPE by refusing to provide an iPad.
What the ALJ Found
The ALJ ruled in the district's favor, finding that Student failed to prove by a preponderance of the evidence that the district denied him a FAPE.
The ALJ found that the district did meaningfully consider the ATEC report. The ATEC assessment had recommended a touch interface generally — not exclusively an iPad — and had also recommended typing practice, mouse use, and a training plan. The district responded by implementing a 60-day touchscreen trial, which was a reasonable response to the report's recommendations. The trial produced credible evidence from experienced teachers, an occupational therapist, and an AT assessor, all of whom observed that Student struggled with the device at school and benefited more from concrete, hands-on methods.
The ALJ also noted that under federal special education law, districts are not required to provide the program or device a parent prefers, or even the one that might produce the greatest educational benefit — only one that is reasonably calculated to provide some educational benefit. The district's decision to use manipulatives and continue OT services met that standard. The ALJ gave limited weight to ATEC's October 2012 follow-up report (which more strongly recommended an iPad), because IEPs must be judged based on what was known at the time they were developed — not in hindsight. Finally, the ALJ acknowledged that district staff lacked experience with iPads and that iPads were not in the district's lending library, but found those facts did not override the legitimate educational conclusion reached after the trial.
What Was Ordered
- Student's request for relief was denied in full.
- The district was found to be the prevailing party.
Why This Matters for Parents
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An independent assessment recommendation is not automatically binding on the district. Even if a qualified expert recommends a specific device like an iPad, the district is permitted to consider that recommendation and respond with a different approach — as long as it is reasonable and designed to provide some educational benefit. The district must genuinely consider the report, not ignore it, but it does not have to follow it.
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What happens at home does not automatically translate to school. The ALJ placed significant weight on how Student performed in the school setting during the 60-day trial, not on how he used the iPad at home. If you are requesting an AT device for school, document your child's performance in school-like tasks and settings, not just at home.
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A 60-day trial is a legitimate process — but watch how it is run. The district used the trial period to gather evidence. Parents should monitor trials closely, communicate observations to the team in writing, and ask for specific data to be collected. If the trial device is not set up to match the recommended device (for example, a heavy desktop instead of a portable tablet), document that difference and raise it at the IEP meeting.
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IEPs are judged on what the team knew at the time, not what is learned later. Evidence gathered after an IEP is developed — including a second independent assessment — carries limited legal weight. If you have new information, request an IEP meeting promptly so it can be considered in real time, rather than waiting for due process.
Note: These summaries are for educational purposes only. OAH decisions are fact-specific and may not apply to your situation. Consult an advocate or attorney for advice about your case.