Special Education Child Entitled to 100% Reimbursement for Needed Supplemental Education, Even if Private School Does Not Fulfill All of Child's Needs

Under the Individuals with Disabilities in Education Act, if a public school fails to provide a special-education student with a free and appropriate public education, and a private placement provides that education, the child is entitled to reimbursement for the private education.  In C.B. v. Garden Grove Unified School District, published March 28, 2011, the Ninth Circuit held that although a hearing officer can reduce the amount reimbursed based on equitable factors (such as the reasonableness of the charges), the officer cannot award less than 100% reimbursement on the ground that the private school does not provide all of the educational services the student needs.