In Marple Newton School District v. Rafael N. ex rel R.N., 48 IDELR 184 (E.D. Pa 2007), a court concluded that an IEP was deficient because there were no "measurable postsecondary goals related to training, education, employment, and independent living skills for a Spanish-speaking mild to moderately retarded 17-year-old special education student with untreatable epilepsy. With regard to the IEP, the court stated the "goals are vague and do not capitalize on the student's strengths or specific interests." Furthermore, the student's IEP "states generic goals that have remained static from year to year. There were no vocational or independent learning outcomes in the community component of the IEP, there was no component to prepare the student for medical self-monitoring, and the IEP did not "take into account the student's strengths or preferences." IEP teams need to be mindful when creating transition plans and ensure that each one is individualized and meaningful.
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