Jonathan Miranda, et al. v. Palo Alto Unified School District, et al.

[3] 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA [6] 7 JONATHAN MIRANDA, et al., Case No. 25-cv-06745-EKL 8 Plaintiffs, ORDER DENYING MOTION FOR 9 v. PRELIMINARY INJUNCTION 10 PALO ALTO UNIFIED SCHOOL Re: Dkt. No. 7 DISTRICT, et al., [11] Defendants. [12] 13 Plaintiffs Jonathan and Sarah Miranda bring this action against the Palo Alto Unified 14 School District (“Palo Alto”) and the California Office of Administrative Hearings (“OAH”) under 15 the Individuals with Disabilities Education Act (“IDEA”) on behalf of their son, J.M. (“Student”). 16 Now before the Court is Plaintiffs’ motion for preliminary injunction seeking a “stay put” order. 17 Mot. for Prelim. Inj., ECF No. 7 (“Motion”). Plaintiffs ask the Court to order Palo Alto “to fund 18 Hope Technology as Student’s stay put placement” during the pendency of this litigation. Id. at 1. 19 For the following reasons, Plaintiffs’ motion is DENIED. 20 “A motion for stay put functions as an ‘automatic’ preliminary injunction, meaning that the 21 moving party need not show the traditionally required factors (e.g., irreparable harm) in order to 22 obtain preliminary relief.” Joshua A. v. Rocklin Unified Sch. Dist., 559 F.3d 1036, 1037 (9th Cir. 23 2009). A stay put order prevents “premature removal of a disabled child to a potentially 24 inappropriate educational setting” during the pendency of proceedings involving a student’s free 25 appropriate public education (“FAPE”), including a civil action. Id. at 1038, 1040 ; 20 U.S.C. 26 § 1415(i)(2). The stay put provision mandates that, “unless the State or local educational 27 agency and the parents otherwise agree, the child shall remain in the then-current educational 1 Here, the parties dispute whether Hope Technology – a private school unilaterally selected 2 by Plaintiffs – is Student’s current educational placement. “Courts have generally interpreted the 3 phrase [current educational placement] to mean the placement set forth in the child’s last 4 implemented IEP [i.e., Individualized Education Plan].” L.M. v. Capistrano Unified Sch. Dist., [5] 556 F.3d 900, 911 (9th Cir. 2009) (collecting cases); see also Rocklin, 559 F.3d at 1037 . 6 However, “where a parent prevails in an administrative hearing and an administrative ruling 7 agrees with the parent that a different placement is appropriate, then . . . it is that new placement 8 that must be made and maintained for purposes of the stay put provision.” S.C. v. Lincoln Cnty. 9 Sch. Dist., 16 F.4th 587, 589-90 (9th Cir. 2021). “Where the agency or the court has ruled on the 10 appropriateness of the educational placement in the parents’ favor, the school district is 11 responsible for appropriate private education costs regardless of the outcome of an appeal.” 12 Capistrano, 556 F.3d at 912 . 13 Plaintiffs contend that Hope Technology is Student’s current educational placement 14 because Plaintiffs prevailed against Palo Alto in the administrative proceedings. See 7/11/25 15 OAH Decision, ECF No. 1-1. After conducting a due process hearing, Administrative Law Judge 16 Robert G. Martin found that Palo Alto engaged in multiple procedural violations of the IDEA. See 17 id. at 20-21, 33-35, 45, 52, 62-66, 75-76, 82. Among these violations, Palo Alto predetermined 18 Student’s IEP, failed to conduct certain observations and assessments of Student, failed to retain 19 and provide assessment protocols to Plaintiffs, and failed to involve Plaintiffs in developing 20 Student’s IEP and transition plan. Id. To remedy these violations, ALJ Martin held that Plaintiffs 21 were “entitled to relief that is ‘appropriate’ in light of the purposes of the IDEA.” Id. at 84. ALJ 22 Martin granted Plaintiffs’ request for “an order directing Palo Alto to reimburse [Plaintiffs] for the 23 costs of Student’s private placement at Hope Technology Academy for the 2023-2024 and 202424 2025 school years.” Id.; see also id. at 89. In finding that reimbursement was warranted, ALJ 25 Martin held that “Hope Technology was an appropriate placement for Student,” and that Plaintiffs’ 26 “placement of Student at Hope Technology was proper under the IDEA.” Id. at 86. 27 ALJ Martin’s decision does not establish that Hope Technology is Student’s current 1 placement, [courts] will not imply a ‘current educational placement’ for purposes of § □□□□□□□□ 2 Capistrano, 556 F.3d at 913 . Here, ALJ Martin did not reach the merits of Student’s placement — 3 that is, he did not address whether Hope Technology would offer Student a FAPE.' Although ALJ 4 || Martin remarked that Hope Technology was “‘an appropriate placement,” this statement was made 5 in the context of finding that reimbursement was appropriate under § 1412(a)(10)(C)Gi). See 6 || 7/11/25 OAH Decision at 85 (citing 20 U.S.C. § 1412 (a)(10)(C)Gi)). The Ninth Circuit has 7 consistently held that a reimbursement award under Section 1412(a)(10)(C)@i) is not a decision on 8 the merits of a student’s placement. Capistrano, 556 F.3d at 912 n.9; see also Irvine Unified Sch. 9 || Dist. v. Landers, Nos. 22-55286, 22-55287, 2023 WL 8915431 , at *1 (9th Cir. Dec. 27, 2023) 10 (“[W Je will construe a reimbursement order as establishing a ‘current educational placement’ for 11 purposes of stay-put relief only if the order ‘expressly find[s] that the private placement [is] 12 appropriate’ for such a purpose.” (quoting Capistrano, 556 F.3d at 913 )). 5 13 In sum, although Plaintiffs prevailed in some respects in the administrative proceedings, 14 || Plaintiffs have not established that Hope Technology is Student’s current educational placement 3 15 for purposes of a stay put order. In awarding reimbursement of costs, ALJ Martin did not a 16 || expressly address the merits of Student’s educational placement and did not reach the issue of a 3 17 stay put order. Therefore, the Court finds that OAH’s subsequent order denying Plaintiffs’ request 18 for a stay put placement at Hope Technology was correctly decided and consistent with the 19 || Court’s own review of the record. See 8/6/2025 OAH Decision, ECF No. 7-4. Accordingly, 20 || Plaintiffs’ motion is DENIED. 21 IT IS SO ORDERED. 22 Dated: November 19, 2025 [24] Eumi K. Lee 25 United States District Judge [26] 07 ' Although ALJ Martin found multiple procedural violations, he expressly declined to address whether Palo Alto’s proposed placement was appropriate. 7/11/25 OAH Decision at 75-76, 82; 2g || see also id. at 86 (finding that reimbursement was appropriate because “Palo Alto did not engage during the IEP process”).