Lessard v. Wilton-Lyndeborough Cooperative School District, 49 IDELR 2, 180,518 F.3d 18 (1st Circuit, 2008)

According to the 1st Circuit Court, the parents in the case "read far too much into Congress' 1997 definition of transition services." It was their assertion that the Rowley standard of "some educational benefit" was no longer applicable with regard to transition services. In their decision the Court clarified the meaning of "outcome oriented process" in the IDEA's definition of transition services: "It specifies the perspective that participants in the process should strive to attain but does not establish a standard for evaluating the fruits of that process." The parent's argument that the student's IEP was inadequate and incomplete because it did not contain a separate "transition plan" was dismissed. The IEP in this case included several various transition services that were scattered throughout the document and "merely pointing to the absence of a stand-alone transition plan cannot form the basis for a founded claim of procedural error."