Golden Gate University Law Review


Caren Jenkins


In Dreher v. Amphitheater Unified School Dist., the Ninth Circuit held that a school district need neither provide nor bear the cost of providing certain individualized educational services to students with disabilities. A school district must furnish only those services outlined in an individualized education plan (hereinafter "IEP"), developed annually by the local educational agency, for each individual with a disability. Required to supply a free appropriate education by federal law, a school district must offer the special education and related services necessary to meet the unique needs of the individual. However, a school district has no responsibility to render or pay for any special education or related services beyond those specified in the IEP. Additionally, with regard to education for children with disabilities, the Ninth Circuit ruled that until a party exhausts available administrative remedies provided by federal law, courts lack subject matter jurisdiction to review complaints.