Showing posts with label hearing. Show all posts
Showing posts with label hearing. Show all posts

Special Education Law 101 - Part XVI: Hearing Procedures

Caricature of Leonard Courtney MP, 1832-1918. ...
Image via Wikipedia


























This is another in a  series of posts comprising an introduction to special education law.  This series is meant to be an introduction for newbies and a refresher course for more experienced readers.  Please let us know what you think about the series.

Today's post and the next post concern some unusual procedural issues in due process hearings.  The due process hearing is the administrative law equivalent of a trial in a civil action.

A.   Hearing Procedures

1.    5 day Disclosure Rule
This rule provides that where a party does not disclose its evidence (generally at least an exchange of exhibits and list of witnesses) at least five business days prior to the due process hearing, such evidence may not be admitted.
34 C.F.R. § 300.512(a)(3), & (b)(1)-(2); IDEA, § 615(f)(2) (evaluations only).

 (Most hearing officers do not like the technicality nature of the 5 day rule.  Most will enforce if a continuance or other procedural maneuver will not cure it.)


2.    Sufficiency of Due Process Complaint
The reauthorized statute provides that a party receiving a due process complaint may challenge the sufficiency of the complaint within 15 days of receipt.  The due process hearing officer must make a determination on the face of the complaint (and notice) concerning sufficiency within 5 days.
IDEA, § 615 (c)(2); 34 C.F.R. § 300.508 (d). 

(Most  courts have imposed a relatively deferential standard for sufficiency.  See,  Anello v. Indian River Sch Dist 107 LRP 7179 (Del. Family Ct. 1/192007)


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Live from San Antonio

Flag of the City of San Antonio for fair use t...
 (Photo credit: Wikipedia)








I am enjoying the annual conference of the National association of Hearing Officials in San Antonio. NAHO is a great organization for administrative hearing officers. 

NAHO has a certification program that allows hearing officers to achieve certification through experience and continuing education. It also has an outstanding annual conference,  I'm pleased to be a part of the regular faculty at these conferences.  The conference serves as both a place to network and to see old friends as well as a continuing education opportunity.

And San Antonio is a fantastic city!

A more detailed report will follow. 
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Procedural Safeguards - The Series Part X

WASHINGTON - MARCH 02:  The U.S. Supreme Court...
WASHINGTON - MARCH 02: The U.S. Supreme Court Building is seen on March 2, 2010 in Washington, DC. Today the high court is hearing arguments in the case of McDonald v the City of Chicago case that questions whether the Second Amendment is incorporated into the due process clause or the privileges or immunities clause of the fourteenth amendment, thus invalidating the city's handgun ban. (Image credit: Getty Images via @daylife)






This is the tenth installment in a multi-part series on procedural safeguards under the federal special education law, the Individuals With Disabilities Education Act. I work a lot in this area, so it is near and dear to my heart. Despite the importance of procedural safeguards. however, many issues in this area are misunderstood. I hope that the special education stakeholders who read this blog find the information in this series helpful.


Due Process Hearings


A due process hearing resembles a court trial. Increasingly, parties are represented by lawyers. Opening statements are made. Testimony is provided by parents, teachers, related service providers, administrators, and many others- often by expert witnesses. Although the formal rules of evidence are generally not applied, exhibits, or documentary evidence, are offered and admitted. The tone is increasingly adversarial. Either closing arguments are made or written briefs are submitted. Hearing officer decisions are generally lengthy and legalistic in tone. The decision of the hearing officer may be appealed to one or more courts.

Parents and local education agencies may file a due process complaint for any matter related to the identification, evaluation, educational placement or the provision of a free and appropriate public education to a child with a disability. IDEA §§ 615(f);615(b)(6).

IDEA imposes a two-year statute of limitations on due process complaints. Unless state law imposes a contrary limitations period, a party must request a due process hearing within two years of the date that the party knew or reasonably should have known about the alleged action that forms the basis of the complaint. § 615 (f)(3)(C). The statute of limitations recognizes two exceptions – cases in which the parent was prevented from requesting the hearing due either to specific misrepresentations by the LEA that it had resolved the problem or to the LEA’s withholding of information that the IDEA requires it to provide. § 615 (f)(3)(D). OSEP has clarified that a state may adopt a statute of limitations either shorter or longer than two years by statute or regulation, but not by common law, subject to the notification provisions of IDEA. 71 Fed. Register No. 156 at pages 46696-97 (August 14, 2006). It is the province of the hearing officer to determine whether a specific complaint has been filed within the statute of limitations and whether an amended complaint relates to a previous complaint. 71 Fed. Register No. 156 at pages 46698 (August 14, 2006).

In addition to the requirement that a hearing officer not have a personal or professional interest that would conflict with objectivity, three more qualifications for due process hearing officers were added in 2004. The following new qualities are required in a hearing officer: the knowledge and ability to conduct hearings in accordance with standard legal practice; the knowledge and ability to write decisions in accordance with standard legal practice; knowledge of and ability to understand special education law. § 615 (f)(3)(A)(ii)-(iv). The changes in the qualifications for hearing officers are significant. The fact that the Congress amended this section signals at least some concern about hearing officers. SEA personnel who train and select hearing officers need to be mindful of these changes to the law. Those who train hearing officers should be people with experience in conducting due process hearings and in writing decisions thereafter. New hearing officers should be able to cite prior experience concerning these qualifications. OSEP has noted that pursuant to its general supervisory responsibility, each SEA must ensure that its hearing officers are sufficiently trained to meet the new qualifications established by IDEA. 71 Fed. Register No. 156 at page 46705 (August 14, 2006).

IDEA provides that the party requesting the due process hearing “…shall not be allowed to raise issues at the due process hearing that were not raised in the (due process hearing) notice…,” unless the other party agrees. § 615 (f)(3)(B). see, 34 CFR §300.511(d); 71 Fed. Register No. 156 at pages 46705 -06 (August 14, 2006). However, note that IDEA § 615 (o) provides that nothing in § 615 “… shall be construed to preclude a parent from filing a separate due process complaint on an issue separate from a due process complaint already filed.”

OSEP noted that states have considerable latitude in developing procedural rules for due process hearings and that determinations upon procedural matters not specifically addressed by IDEA are within the sound discretion of the hearing officer so long as the parties’ right to a timely hearing is not denied. 71 Fed. Register No. 156 at page 46704 (August 14, 2006). Other items left to the discretion of the hearing officer include the following: decisions concerning appropriate expert witness testimony. 71 Fed. Register No. 156 at page 46691 (August 14, 2006); ruling upon compliance with timelines and the statute of limitations. 71 Fed. Register No. 156 at page 46705 (August 14, 2006); determining when dismissals are appropriate. 71 Fed. Register No. 156 at page 46699 (August 14, 2006); whether the non-complaining party may raise other issues at the hearing that were not raised in the due process complaint. 71 Fed. Register No. 156 at page 46706 (August 14, 2006); the meaning of the word “misrepresentation” for purposes of the exception to the statute of limitations for filing a due process complaint. 71 Fed. Register No. 156 at page 46706 (August 14, 2006); and providing proper latitude for pro se parties. 71 Fed. Register No. 156 at page 46699 (August 14, 2006).

Concerning the five business day rule for disclosure of evidence prior to a due process hearing, OSEP commented that nothing prevents parties from agreeing to a shorter period of time. 71 Fed. Register No. 156 at page 46706 (August 14, 2006).

As to the location and time of due process hearings, OSEP resisted the suggestion that they be conducted in a “mutually convenient” time and place, fearing that the large number of participants to a hearing would necessitate long delays if mutually convenient times and locations were required. The regulations retain the requirement that hearings be conducted at a time and place that is reasonably convenient to the parents and student. 34 CFR § 300.515(d); 71 Fed. Register No. 156 at page 46707 (August 14, 2006).

Representation by Non-Attorneys in Due Process Hearings

Changes to the federal IDEA regulations effective on December 31, 2008 made an important change to the policy interpretation by OSEP regarding the representation of parties (primarily parents) by non-lawyers in due process hearings. Prior to the change, it had been the long-standing interpretation of OSEP that a non-lawyer could represent parents at a due process hearing in much the same way that a lawyer could represent a party. After certain lower courts declared such a practice to be a violation of “unauthorized practice” statutes, OSEP changed 34 C.F.R. Section 300.512 (a)(1) to specify that whether a party has the right to be represented by a non-lawyer at a due process hearing shall be determined by state law.

Some commenters, including this author, asked OSEP to clarify whether it was sufficient for a state by rule or regulation to specify that parties could be represented by non-lawyers or whether the ability of a lay advocate to represent parents is instead controlled by state law regarding the unauthorized practice of law. OSEP’s “response” was as follows:

Discussion: Whether an SEA may have a State regulation or procedural rule permitting non-attorney advocates to represent parties at due process hearings or whether that issue is controlled by State attorney practice laws is determined by State law. If State law is silent on the question of whether non-attorney advocates can represent parties in due process hearings, there is no prohibition under the Act or its implementing regulations on nonattorney advocates assuming a representational role in due process hearings. 73 Fed Register No. 231 at page 73018 (12/1/2008)

Here is the OSEP Topic Brief on Due Process Hearings:

 Here is the OSEP Questions and Answers On Procedural Safeguards and Due Process Procedures For Parents and Children With Disabilities:



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More Fun With Numbers: The CADRE Stats 2009-2010

Evolução do preço do petróleo cru
Evolução do preço do petróleo cru (Photo credit: Wikipedia)






One important requirement that the federal government takes very seriously in the realm of special education is data.  Gotta have lotsa data. For those of us who are arithmetically challenged, these are also know as numbers or figures.  Lest I get too folksy, ...

One of the many excellent services that the great people at CADRE offer is to make sense of the dispute resolution data.  If you are interested in special education, you should be aware of these data compilations.

The new information was posted on the CADRE website recently. You can find the CADRE website here. 

If you are interested in how your state compares with others over the last five school years in terms of numbers of mediations, due process hearings and state complaints, you should check out the tables.  Particularly useful are the tables showing numbers of dispute resolution events by 10,000 special education students.  These charts allow comparisons not altered by differences in population or number of students served.

Here are a few quotes from the introduction to the data analysis by Dr. Dick Zeller of CADRE:

"Nationally, the filing of written state complaints peaked in 2004-05 (6,201) and has declined by more than 20% since then (see Table 1). Complaint reports issued and complaint reports with findings have decreased even more over the same period (30.3% and 28.9%, respectively)...

The number of mediations reported (see Table 2) peaked in 2004-05 (7,121), then declined sharply in 2005-06 and 2006-07 as the resolution process was implemented. Most of that decrease in mediation activity was in mediations related to due process; it appears that the resolution process was not only an additional dispute resolution option, but also initially replaced what would have been mediations held related to due process complaints. For three years, the number of mediations held then increased again to 6,054 mediations in 2008-09, with 4,246 agreements reached, followed by a decline in mediation activity for 2009-10. . From 2004-05 to 2005-06 due process related mediation as a percentage of all mediation activity dropped for both mediations held (from 60% to 50%) and for mediation agreements (from 58% to 44%), then has varied in the past four years. A shift away from due process related mediation may reflect an increased interest in using third party neutrals to assist parents and schools to resolve due process complaints in the resolution process, particularly where strained relationships may benefit from external support...

Due process (DP) complaint filings peaked in 2004-05, rising to over 21,000 filings (see Table 3). Since then, due process filings have declined by just over 18% to just 17,228 in 2009-10. The reported number of fully adjudicated due process hearings also peaked in 2004-05 and has declined sharply (by >68%) over the past years. The percentage of DP complaints that result in a hearing has declined substantially over these six years (from 35% to 14%, although about 75% of this reduction is due to one entity’s reduction in activity). The percentage of pending DP complaints has increased over the same period from 11% of requests to 145 to 16% of requests (the peak in pending hearings in 2007-08 nationally can be attributed largely to two states). The increase in pending complaints is likely due, at least in part, to the effective increase in the timeline when the resolution process runs its full 30 days...

The percentage of due process complaints resolved without a hearing has grown with the implementation of the resolution process (from 54% of filings in 2004-05 to 70% in 2009-10). The proportion of these resolutions that are the result of a Written Settlement Agreement increased to about 25% in 2009-10. If this trend continues, it suggests that the resolution agreement process is indeed having a positive impact on the resolution of due process complaints without resorting to a hearing. A few states have included summaries in their APRs that breakdown of “resolved without a hearing” into subcategories (e.g., by written settlement agreement, by other settlement after the resolution period, by DP related mediation agreement, by DP complaint withdrawal, by Hearing Officer insufficiency determination), but comparable national data of this sort does not exist across states..."

CADRE and Dr. Zeller welcome questions from the field about the data.

Here are a few other gems that I have unearthed to whet your appetite.  In school year 2009-2010 the number of mediations per 10,000 special ed kids in the following states was: Massachusetts 57.3; California 39.4; Connecticut 39.3; Louisiana 0.8; South Carolina 0.5; Georgia 0.0.

Also for school year 2009-2010: the number of due process hearings held per 10,000 special ed kids were: District of Columbia 248; Hawaii 21; New York 9.2; New Jersey 2.4; Pennsylvania 2.2; Michigan 0.2; Minnesota 0.2; Kentucky 0.1. I'm not sayin'...I'm just sayin'  ...

You can review the charts and the data plus the CADRE analysis of the data  here.  Let me know what you find.
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More Thoughts on Dispute Resolution; Tech Update

It is pretty rare that I make it all the way around all of those mountains to get to the Northern Panhandle of West Virginia.  It is a long ride.  This year I have already been there twice.  And yes this does mean that I passed by my favorite road name again. (See photo above.) I also drove very slowly through the speed trap formerly known as "McMechen."

More importantly, I again was able to contrast the value of mediation as a tool for dispute resolution in special education.  I serve as both a hearing officer and as a mediator.  I also train hos and mediators.  I continue to believe strongly that mediation is the better way to go.  Mediation is better suited to resolve those relationship issues which are so critical to the education of a child.  This is one of the topics that I discuss on the CADRE interviews, which you can find here.  By the way, there is a wealth of other useful information about special ed dispute resolution in these interviews.

Also a quick tech update.  The LinkedIn special education law group continues to prosper with over 2650 members.  Check it out.  The Facebook Special Education Law Group was "archived" by the evil corporate masters of Facebook because members were not updating their status every five seconds. That still burns.

I do have a question for readers though.  Before the new timeline, Facebook used to list my blog posts on my notes section automatically after I tinkered with the settings.  This stopped and I wonder if there is a way to automatically have my blog posts appear on Facebook? Any ideas?

The best way to support the blog is to take one of the free subscriptions available on the left hand side of the blog.  Numbers count in the blogosphere. You can get the posts delivered to your email inbox, or via RSS feed.  You can even get a blidget (=blog + widget) to place inside your own website or blog.   Thanks again to all our readers.
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The CADRE Interviews: Must See TV

Bottom view of VHS videotape cassette with mag...Bottom view of VHS videotape cassette with magnetic tape exposed (Photo credit: Wikipedia)

Occasionally being famous is not good, but this is not one of those stories...

I am almost famous yet again.  Seriously though, I was recently honored by CADRE, the OSEP funded national technical assistance center that specializes in dispute resolution in special education.  CADRE's most recent project is "voices from the field." CADRE interviewed ten experts in special education dispute resolution as well as representatives from its four exemplar states and recorded the interviews.  I was lucky enough to be among those interviewed.

You can see the videos of the interviews, including mine, here. There is a wealth of information about this field on the videos. I recommend them highly.  But remember, the CADRE staff are not plastic surgeons; the video of me pretty much looks like me, so take all appropriate cautions when viewing!

Seriously, though, CADRE is a fantastic organization and if you work in the special education dispute resolution field, you should be familiar with the wealth of resources on their website.  There is a permanent link to the CADRE website on the left hand side of the blog.  You can also find it here. Check out these user friendly resources.

Thank you CADRE for another useful tool.
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McMechen: Speed Trap!

English: Marcellus Shale bank along Rt 174 jus...Image via Wikipedia




OK so here in West Virginia, we are having a natural gas rush created by the Legislature's recent approval of the removal of natural resources from the Marcellus Shale deposit. As a result of this new gas rush, I could not find a motel in Moundsville for a recent hearing. Accordingly, I had to stay in Wheeling, to the North.

Therein lies the problem, squarely in between lies McMechen.  I had to pass McMechen twice each day of the three day hearing.  You would think that the story would more likely involve the venue of the hearing, the former state prison in Moundsville, a place so bad that the West Virginia Supreme Court of Appeals ruled was cruel and unusual punishment.

Yet McMechen stole the headlines.I thought the speed limit was 65 mph along the highway known as Route 2.  This seemed especially so in view of the many cars whizzing past me as I traveled along at a safe 55 mph.So it was to my great surprise when I was stopped by a very, very young police officer and issued a citation for traveling at 55 mph in a 50 mph zone.

So a warning to the traveler, if you must drive through the Northern panhandle of West Virginia, go slowly trough the speed trap also known as McMechen!


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Mediation vs Hearings: SpEd Dispute Resolution

MediationImage by TomNatt via Flickr


This week I finished a decision from a due process hearing and I conducted a mediation.  Dangerous combination.  This got me to thinking about dispute resolution under IDEA.  I have long contended that mediation is a better way to resolve special education disputes. 

A due process is increasingly like a court trial.  Very adversary in nature; lots of venom.  There is of course plenty of place for venom in our society.  (Otherwise we wouldn't really need lawyers would we?)  I'm just not sure that the education of a child is one of them.  Don't get me wrong, I love doing hearings.  I have been doing some type of work as a hearing examiner, hearing officer, administrative law judge as a part of my job since 1979.  I train hearing officers, special ed and others; I am a certified hearing official.  But this is really not about me, it is about those kiddos with disabilities.

Mediation unlike the adversary hearing offers the possibility of repairing the troubled relationship between parent and school officials.  Because education demands cooperation and collaboration between parents and the schools, mediation can really be a good way to go in the long run.  I have talked to parents who won a due process hearing, but still felt like they had lost.  There is an emotional cost in using the hearing process, and it can be significant.

There are situations that require the hearing process, but from my vantage point, mediation is often a better road.  

What do you think?
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NAHO Conference

Santa Fe, New MexicoImage by gholmes via Flickr
The conference of the National Association of Hearing officials was the final stop on the Jim Gerl 2011 tour.  The conference was held in mid November at the historic La Fonda hotel in beautiful Santa Fe, New Mexico.   

The meeting was a great opportunity to see old friends and to meet other hearing officers.  The educational sessions were top notch and the participation by the New Mexico justice system was very helpful.

NAHO is an organization of administrative hearing officers.  It includes representatives from welfare agencies, DMVs, unemployment agencies, workers comp agencies, special education agencies, retirement boards, condo associations, environmental protection agencies, the Nuclear Regulatory Commission, the Parole Commission,  and everything in between.  It is a good mix of people who do all sorts of hearings. The conference is a great opportunity to talk to others who do administrative hearings and to learn from what they do.  

I have served on the faculty of the NAHO annual conference for the last seven years.  This year I presented three sessions.  The first was my favorite How to Conduct an Administrative Hearing.  The second was Dealing With Difficult Lawyers and Parties.  The last on was a Nuts & Bolts Approach to Due Process.  My sessions were well attended and those who attended actively participated.  They went well.

A subsequent post will cover some of the other sessions.
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Special Education Law 101 - Part XVI Hearing Issues

Caricature of Leonard Courtney MP, 1832-1918. ...Image via Wikipedia
This is another in a  series of posts comprising an introduction to special education law.  This series is meant to be an introduction for newbies and a refresher course for more experienced readers.  Please let us know what you think about the series.

Today's post concerns some unusual procedural issues in due process hearings.  

A.   Hearing Procedures

1.    5 day Disclosure Rule
This rule provides that where a party does not disclose its evidence (generally at least an exchange of exhibits and list of witnesses) at least five business days prior to the due process hearing, such evidence may not be admitted.
34 C.F.R. § 300.512(a)(3), & (b)(1)-(2); IDEA, § 615(f)(2) (evaluations only).

 (Most hearing officers do not like the technicality nature of the 5 day rule.  Most will enforce if a continuance or other procedural maneuver will not cure it.)


2.    Sufficiency of Due Process Complaint
The reauthorized statute provides that a party receiving a due process complaint may challenge the sufficiency of the complaint within 15 days of receipt.  The due process hearing officer must make a determination on the face of the complaint (and notice) concerning sufficiency within 5 days.
IDEA, § 615 (c)(2); 34 C.F.R. § 300.508 (d). 

(Most  courts have imposed a relatively deferential standard for sufficiency.  See,  Anello v. Indian River Sch Dist 107 LRP 7179 (Del. Family Ct. 1/192007)


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