The District Court for the District of Columbia held a school district’s failure to conduct one of five assessments when conducting an initial evaluation to determine her eligibility under the IDEA rendered the entire evaluation deficit and ordered the school district to fund an entirely new Independent Education Evaluation (“IEE”), which would encompass areas of assessment the District had properly conducted. In making this determination, the Court emphasized the IDEA defines “evaluation” and “assessment” differently, with various assessments making up an evaluation or re-evaluation. As a result, “when ‘a parent requests an [IEE],’ the school must grant that request unless it can demonstrate to an administrative hearing officer ‘that its evaluation is appropriate,’” meaning the District must demonstrate all the underlying assessments are appropriate. A District “cannot defend only some of the underlying” assessments. If, as was the case here, a District can only defend some of its assessments as being appropriate, or it failed to conduct assessments deemed necessary and appropriate for a student, a parent is entitled under the IDEA to an IEE in all assessment areas “necessary to formulate that evaluation.”

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