In L.F. by Ruffin v. Houston Independent School District, 53 IDELR 116 (S. D. Texas 2009), the court concluded a school district met FAPE requirements when it placed a fifth grade girl with an emotional disturbance in a self-contained program designed to address behavior, academics, and social skills. The placement was determined to be the least restrictive environment as the student was mainstreamed for study hall and physical education. Although the parent charged the district with procedural violations, paperwork indicated the parent was informed of the placement and received appropriate and timely notification of IEP meetings. Cypress-Fairbanks Independent School District v. Michael F., 26 IDELR 303 (5th Circuit 1997) outlined 4 prongs used to determine whether or not a special education program is appropriate: (1) addresses student's individual needs; (2) is administered in the LRE; (3) is implemented in a coordinated and collaborative manner by key stakeholders; and (4) allows the student to obtain academic and nonacademic benefits. The district met all four elements in this case and the court rejected the parent's substantive claim as well.
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