rior to the  amendment of the IDEA . . . , the time for bringing suit . . . after receiving an adverse administrative determination had b een two years”). Case: 14-1387 Document: 003112081189 Page: 35 Date Filed: 09/22/2015 36 child’s right to compensatory education “accrue[s] from the point that the school district knows or should know” of the injury to the child, and the child “is entitled to compensatory education for a period equal to the period of deprivation, but excluding the time reasonably required for the school district to rectify the problem.” M.C. ex rel. J.C. v. Cent. Reg’l Sch. Dist. , 81 F.3d 389, 396 -97 (3d Cir. 1996); see also D.F. , 694 F.3d at 499 (repeating standard); Mary T. v. Sch. Dist. of Phila. , 575 F.3d 235, 249 (3d Cir. 2009) (same); Lauren W. ex rel. Jean W. v. DeFlaminis , 480 F.3d 259, 272 (3d Cir. 2007) (same). That standard is grounded in our understanding, then and now, that “a child’s entitlement to speci al education should not depend upon the vigilance of the parents (who may not be sufficiently sophisticated to comprehend the problem) nor be abridged because the district’s behavior did not rise to the level of slothfulness or bad faith.” M.C. , 81 F.3d a t 397. Again st the backdrop of these cases and the broad interpretation the Supreme Court has given to a court’s remedial power under § 1415(i)(2)(C)(iii) , it bears particular significance that Congress reenacted that subsection without change as part of t he 2004 reenactment. Thus, interpreting the IDEA’s statute of limitations as a remedy cap would also disregard the well -settled canon of statutory interpretation that “Congress is presumed to be aware of an administrative or judicial interpretation of a s tatute and to adopt that interpretation when it re -enacts a statute without change .” Lorillard v. Pons, 434 U.S. 575, 580 (1978) ; see also Tex. Dep’t of Hous. & Cmty. Affairs v. Inclusive Communities Project, Inc. , 135 S. Ct. 2507, 2520 (2015) . On this po int , we find clear guidance in the Supreme Court’s decision in Forest Grove , which examined the 1997 Case: 14-1387 Document: 003112081189 Page: 36 Date Filed: 09/22/2015 37 amendments to the IDEA. Those amendments added, among other thing s, § 1412(a)(10)(C), which provided that if the parents of a special -needs child “who pre viously received special education and related services under the authority of a public agency” enrolled their child in private school without the consent or referral of that public agency, a school district could still be ordered to provide tuition reimbu rsement if a fact -finder determined that the school district failed to provide a student with a FAPE in t he first instance. 20 U.S.C. § 1412(a)(10)(C)(ii). In an attempt to limit liability, a school district argued that because the IDEA “only discusses reimbursement for children who have previously received special -education services through the public school, [the] IDEA only authorizes reimbursement in that circumstance.” 557 U.S. at 241. The Supreme Court disagreed. It observed that the 1997 amendme nts preserved the IDEA’s comprehensive remedial goal of providing every child with a FAPE and did not alter 20 U.S.C. § 1415(i)(2)(C)(iii) . See id . at 243 n.10 (stating that the holdings in School Committee of Burlington v. Department of Education of Mass achusetts , 471 U.S. 359 (1985), and Florence County School District Four v. Carter , 510 U.S. 7 (1993), “rested . . . on the breadth of the authority conferred by § 1415(i)(2)(C)(iii), the interest in providing relief consistent with the Act’s purpose, and the injustice that a contrary reading would produce — considerations that were not altered by the 1997 Amendments” (internal citations omitted) ). The Court thus rejected the notion that Congress repealed sub silentio those previous Supreme Court holdings de scribing the “ broad discretion” afforded by § 1415(i)(2)(C)(iii) . Id. at 243. Any other reading, the Court reasoned, would be contrary to the IDEA’s broad remedial Case: 14-1387 Document: 003112081189 Page: 37 Date Filed: 09/22/2015 38 purpose and a “child’s right to a free appropriate education . . . would be less than comp lete.” Id . at 244 -45 (alteration in original) (quoting Burlington , 471 U.S. at 370) . So too here, for the 2004 reauthorization reaffirmed the IDEA ’s first purpose as “ensur[ing] that all children with disabilities have available to them a free appropriate public education . . . designed to meet their unique needs ,” 20 U.S.C. § 1400(d)(1)(A), and once more left unchanged § 1415(i)(2)(C)(iii) , which grants courts the broad discretion to fashion remedies t hat accomplish that objective . Congress’s purpose in that mandate is clear: In order to effectuate the law’s broad remedial goals , a court finding a deprivation of a free appropriate public education should return a child to the educational path he or she would have traveled had the educational agency provi ded that child with an appropriate education in the first place . See D.F. , 694 F.3d at 498 -99; Reid , 401 F.3d at 518 ; see also Ridgewood , 172 F.3d at 251 (remanding to district court to consider eight years of claims for compensatory education); Lester H. by Octavia P. v. Gilhool , 916 F.2d 865, 873 -74 (3d Cir. 1990) (affirming grant of thirty months of compensatory education). Consistent with that purpose and the traditional way in which a discovery -based statute of limitations functions, courts since the passage of the 2004 reenactment have routinely affirmed awards of compensatory education that remedy d eprivations of greater than two years , or at minimum, remanded for an administrative agency to consider those claims . See Ferren C. v. Sch. Dist. of Phil a., 612 F.3d 712, 715 (3d Cir. 2010) (affirming award of three years of compensatory education); M.S. ex rel. Simchick v. Fairfax Cnty. Sch. Bd ., 553 F.3d 315, 324 (4th Cir. 2009) (holding that the broad discretion afforded under the IDEA allowed a Case: 14-1387 Document: 003112081189 Page: 38 Date Filed: 09/22/2015 39 distric t court to consider reimbursement for three years of a child’s allegedly inappropriate placement); Draper v. Atl. Indep. Sch . Sys. , 518 F.3d 1275 , 1286 -90 (11th Cir. 2008) (rejecting a school district’s argument that a child’s long - undiscovered injury was time barred and upholding an award of approximately five years of compensatory education); Reid , 401 F.3d at 526 (remanding to consider claims over a four and half year period of time); K.H. v N.Y. C. Dep’t of Educ. , No. 12 -1680, 2014 WL 3866430, at *20 (E. D.N.Y. Aug. 6, 2014) (finding that “the IDEA’s clear statutory language mandates” that a remedy is not limited by the statute of limitations when a claim is timely filed); Jefferson Cnty. Bd. of Educ. v. Lolita S. , 977 F. Supp. 2d 1091, 1123 (N.D. Ala. 201 3) (holding that a right to redress for a complaint filed in October 2011 would be limited to the most recent two years “ unless . . . the statute did not begin to run on the claim because the parent did not know/should not have known about that action unti l a time within two years of the due process request”). But see Indep. Sch. Dist. No. 413, Marshall v. H.M.J. , No. 14 -2114, 2015 WL 4744505, at *11 (D. Minn. Aug. 11, 2015) (“No party may recover for a violation occurring outside the two -year statute of limitations.”) . Of course, the IDEA’s statute of limitations does still practically curtail remedy , for i t “specif[ies] when a [complaint] is timely filed” and thus “has the consequence of limiting liability because filing a timely [complaint] is a prerequi site to having an actionable claim.” Nat’l R.R. Passenger Corp. v. Morgan , 536 U.S. 101, 120 (2002). I n context, however, that means simply that once a violation is reasonably discovered by the parent , any claim for that violation , however far back it da tes, must be filed within two Case: 14-1387 Document: 003112081189 Page: 39 Date Filed: 09/22/2015 40 years of the “knew or should have known” date . If it is not, all but the most recent two years before the filing of the complaint will be time -barred ; but if it is timely filed , then, upon a finding of liability, the entire p eriod of the violation should be remedied . In other words, § 1415(f) (3)(C) , like its synopsis in § 1415(b) (6)(B) , reflects a traditional statute of limitations . iii. The Department of Education’s Regulation and Interpretation The DOE , the federal agency charg ed with promulgating regulations for the IDEA, see 20 U.S.C. § 1406, agrees that § 1415(b)(6)(B) and § 1415(f)(3)(C) state the same limitations period . In its regulations following the 2004 reenactment, the DOE simply reproduced both subsections verbati m. Compare 20 U.S.C. § 1415(b)(6)(B), and 1415(f)(3)(C), with 34 C.F.R. §§ 300.507(a)(2), and 300.511(e). In its Analysis of Comments and Changes to those regulations, however, the DOE reported that commenters were confused and sought guidance , “ because the statute of limitations is mentioned twice and implies that the time line for filing a complaint and filing a request for a du e process hearing are different.” Assistance to States for the Education of Children with Disabilities & Preschool Grants for C hildren with Disabilities , 71 Fed. Reg. 46,540, 46,706 (Aug. 14, 20 06). I t responded that “[t]he statute of limitations in section [1415(b)(6)(B)] of the Act is the same as the statute of limitations in section [ 1415(f)(3)(C)] of the Act. ” Id . In this appeal, at our request, the DOE also submitted an amicus letter brief in which it reiterated its position that t he Case: 14-1387 Document: 003112081189 Page: 40 Date Filed: 09/22/2015 41 subsections are, in fact, referencing a single statute of limitations. 17 We afford the DOE’s interpretation of its regulation and its posi tion before us here “‘respect’ . . . to the extent it has the ‘power to persuade,’” Gonzales v. Oregon , 546 U.S. 243, 256 (2006) (quoting Skidmore v. Swift & Co. , 323 U.S. 134, 140 (1944)) ; see id. at 25 6-57 (holding that an agency’s interpretation of regu lations that merely parrot the statute are accorded Skidmore deference, rather than the higher deference generally accorded to interpretive guidance under Auer v. Robbins , 519 U.S. 452 (1997) ). Here, w e find the DOE’s position persuasive because it accord s with the language, structure and purpose of the statute, and it is yet one more voice in a har monious chorus that § 1415(b)(6)(B) was intended to reiterate § 1415(f)(3)(C)’s two -year st atute of limitations. 17 The IDEA also tasks the DOE with promulgating a model notice of procedural safeguards. 20 U.S.C. § 1417(e). In that model notice, it again repeated the language of § 1415(b)(6), but cautioned states that if they “established a specific timeframe for requesting a hearing under the IDEA that is different than two years (either shorter or longer), revise the above statement to reflect that timeframe.” United States Department of Education, Part B Procedural Safeguards Notice, 17 (2009), http://www2.ed.gov/policy/speced/guid/idea/modelform - safeguards.doc. Again, such a caution to revise the limitations notice shorter or longer based on a state’s statute of limitations only makes sense if § 1415(b)(6)(B) is, in fact, a statute of limitation s. Case: 14-1387 Document: 003112081189 Page: 41 Date Filed: 09/22/2015 42 To the extent there remains any doubt about th is conclusion, it is put to rest by the legislative history, to which we next turn. iv. The Legislative History of the 2004 IDEA Amendments “Supreme Court cases declaring that clear language cannot be overcome by contrary legislative history are legion.” Firs t Merchs. Acceptance Corp. v. J.C. Bradford & Co. , 198 F.3d 394, 402 (3d Cir. 1999) (collecting cases). That said, legislative history can play a confirmatory role in resolving ambiguity when statutory language and structure support a given interpretation . See, e.g. , Gen. Dynamics Land Sys. v. Cline , 540 U.S. 581, 586 -91 (2004) ; Catwell v. Att’y Gen. , 623 F.3d 199, 208 (3d Cir. 2010). This is such a case. A legislature designing a statute of limitations confronts certain choices . As we have discussed, i t can set the date from which the limitations period begins to run by using the occurrence rule or the discovery rule . See supra at 23-26. It also can set the expiration date either by counting forward from that occurrence or discovery date to the filing of a complaint or by counting backward from the date a complaint is filed to the occurrence or discovery date . When the House of Representatives proposed the amendment that was eventually incorporated into § 1415(b)(6), it chose to use the occurrence ru le and to count backward , providing that parents would have : (6) an opportunity to present complaints – Case: 14-1387 Document: 003112081189 Page: 42 Date Filed: 09/22/2015 43 (A) with respect to any matter relating to the identification, evaluation, or educational placement of the child, or the provision of a free appropriate public education to such child; and (B) which set forth a violation that occurred not more than one year before the complaint is filed; H.R. Rep. 108 -77, at 254 (2003) . The House committee’s report unambiguously described this language as a one -year statu te of limitations. Id. at 115 -16 ( “Statute of limitations [:] The Act currently has no statute of limitations and leaves local educational agencies open to litigation for the entire length of time a child is in school, whether or not the child has been ide ntif ied as a child with a disability. . . . The bill includes a statute of limitations of one year from the date of the violation . . . .). And as written, it would have unambiguously functioned like one, barring claims based on injuries that occurred mor e than twelve months before the complaint was filed. The Senate, meanwhile, chose to use the discovery rule and to count forward, providing in what became § 1415(f)(3)(C): Timeline for requesting hearing. –A parent or public agency shall request an impart ial due process hearing within 2 years of the date the parent or public agency knew or should have known about the alleged action that forms the basis of the complaint, or, if the State has an explicit time limitation for requesting such a Case: 14-1387 Document: 003112081189 Page: 43 Date Filed: 09/22/2015 44 hearing under th is part, in such time as the State law allows. S. Rep. 108 -185, at 222 (2003) . Unlike the House ’s proposal , the Senate’s also added the provision giving primacy to a state’s limitations period , along with the two statutory tolling exceptions. Those t wo bills — both statutes of limitations but pointing in different directions and using different starting dates for the limitations period — then went to conference where the conference committee sought to reconcile them. Th at committee reaffirmed that each b ody’s amendment functioned as a traditional statute of limitations on the filing of a complaint : The House bill and Senate amendment have similar language regarding the opportunity to present complaints, but the House bill, not the Senate amendment, inclu des language establishing a 1 year statute of limitations on the right to present complaints. Senate has a 2 year timeline for filing complaints at note 221. H.R. Rep. 108 -779, at 213 n.193 (2004) (Conf. Rep.) , reprinted in 2004 U.S.C.C.A.N. 2480, 2527 ; se e also id. at 218 n.221 , 2532 (“T he Senate amendment establishes a 2 - year statute of limitations unless State law already has a statute of limitations. The House bill includes a 1 -year statute of limitations (see note 193).”). Apparently c oncluding that the additi on of a statute of limitations sh ould involve both a new provision within § 1415 (f) (3)(C) and an amendment to its prefatory sub section Case: 14-1387 Document: 003112081189 Page: 44 Date Filed: 09/22/2015 45 at § 1415(b)(6) , the conference committee opted not to choose one body’s addition over the other but to retain both. It did so by conforming each and every of the material terms of the House’s version to the Senate’s , i.e., by changing the House’s limitations perio d from one year to two, changing the occurrence rule to the discovery rule, adding that a state ’s statute of limitations could override the IDEA’s , and adding the two equitable tolling provisions specified by the Senate . The conference committee then incorporated the Senate’s version at § 1415(f) and the House’s version in the summary listing at § 1415( b). W hen it did so , however, it omitted to change the backward -looking framework of the House’s version to the forward -lo oking framework of the Senate’s. Thus was created the problem we grapple with today . Section 1415(b)(6) , in other words, started in t he House as a functioning, one -year statute of limitations for the filing of complaints: (A) with respect to any matter relating to the identification, evaluation, or educational placement of the child, or the provision of a free appropriate public educati on to such child; and (B) which set forth a violation that occurred not more than one year before the complaint is filed [.] H.R. Rep. 108 -77, at 254 (emphasis added). It ended, however, as something different altogether: (A) with respect to any matter relating to the identification, evaluation, or educational Case: 14-1387 Document: 003112081189 Page: 45 Date Filed: 09/22/2015 46 placement of the child, or the provision of a free appropriate public education to such child; and (B) which set forth an alleged violation that occurred not more than two years before the date the parent or public agency knew or should have known about the alleged action that forms the basis of the complaint, or, if the State has an explicit time limitation for presenting such a complaint under this subchapter, in such time as the State law allows, except that the exceptions to the timeline described in subsection (f)(3)(D) shall apply to the timeline described in this subparagraph. 20 U.S.C. § 1415(b)(6) (emphasis added). The Congressional Research Service described the amendments this way: The 20 04 reauthorization includes statutes of limitations in various sections. As previously discussed [Section 1415 (b) ] provides for a two -year statute of limitations regarding the filing of a complaint . There is also a two -year statute of limitations regarding requests for a hearing. The two years is from the date the parent or agency knew or should have known about the alleged action. Richard N. Appling an d Nancy Lee Jones, Cong. Research Serv. , RL32716, Individuals with Disabilities Education Act (IDEA): Ana lysis of Changes Made by P.L. 108 -446, CRS -27 (2005) (emphasis added) . While this post -enactment Case: 14-1387 Document: 003112081189 Page: 46 Date Filed: 09/22/2015 47 observation on its own carries little weight, n othing in the IDEA’s legislative history points to a contrary interpretation . In fact, quite the opposite. Far from Congress intending that the two limitations period s diverge or limit a court’s remedial power under § 1415 (i), the legislative his tory reflects that the drafters intended the amendments to add a single statute of limitations and to leave untouched the IDEA’s broad remedies . For example, in its explanation of the addition of the statute of limitations, the Senate report stated: This new provision is not intended to alter the principle under IDEA that children may receive compensatory education ser vices, as affirmed in School Comm. of Burlington v. Department of Education of Massachusetts , 471 U.S. 359 (1985) and Florence County School District Four v. Carter , 510 U.S. 7 (1993) and otherwise limited under section [1412(a)(10)(C)] . . . . In essence, where the issue giving rise to the claim is more than two years old and not ongoing, the claim is barred; where the conduct or services at issue are ongoing to the previous two years, the claim for compensatory education services may be made on the basis of the most recent conduct or services and the conduct or services that were more than two years old at the time of due p rocess or the private placement . . . . S. Rep. 108 -185, 40 (emphasis added). Case: 14-1387 Document: 003112081189 Page: 47 Date Filed: 09/22/2015 48 After conference, but before final passage, Senator Hark in, a co -sponsor of the amendments, addressed the addition of a statute of limitations this way: In this reauthorization, we also include a 2 -year statute of limitations on claims. However, it should be noted that this limitation is not designed to have a ny impact on the ability of a child to receive compensatory damages for the entire period in which he or she has been deprived of services. The statute of limitations goes only to the filing of the complaint, not the crafting of remedy. This is important because it is only fair that if a school district repeatedly failed to provide services to a child, they should be required to provide compensatory services to rectify this problem and help the child achieve despite the scho ol’ s failings. Therefore, compens atory education must cover the entire period and must belatedly provide all education and related services previously denied and needed to make the child whole. 150 Cong. Rec. S11851 ( daily ed. Nov. 24, 2004) (statement of Sen. Tom Harkin) (emphasis added ); see also Robert R. v. Marple Newtown Sch. Dist. , No. 05 -1282, 2005 WL 3003033, at *4 (E.D. Pa. Nov. 8, 2005) (examining the IDEA’s legislative history and concluding that “the limitations period placed on claims for compensatory education by the  amendment to the IDEA was not meant to limit the period which the hearing officer could consider when a due process Case: 14-1387 Document: 003112081189 Page: 48 Date Filed: 09/22/2015 49 hearing was timely brought”) ; Jennifer Rosen Valverde, A Poor IDEA: Statute of Limitations Decisions Cement Second - Class Remedial Scheme for Low -Income Children with Disabilities in the Third Circuit , 41 Fordham Urb. L.J. 599, 643 -646 (2013) . The legislative history is thus crystal clear that Congress intended to impose a single statute of limitations, but otherwise no t to limit a court’s pow er to remedy the deprivation of a free appropriate education. V. Conclusion As a general rule, “[t]he plain meaning of legislation should be conclusive.” United States v. Ron Pair Enters., Inc. , 489 U.S. 235, 242 (1989). However, in the “rare cases [in whi ch] the literal application of a statute will produce a result demonstrably at odds with the intentions of its drafters,” the plain meaning need not control. Id. (alteration in original) (quoting Griffin v. Oceanic Contractors, Inc. , 458 U.S. 564, 571 (19 82 )). In those exceptional instances where “it is uncontested that legislative intent is at odds with the literal terms of the statute, . . . [ our ] primary role is to effectuate the intent of Congress even if a word in the statute instructs otherwise.” M organ v. Gay , 466 F.3d 276, 278 (3d Cir. 2006); accord Thorpe v. Borough of Thorpe , 770 F.3d 255, 263 (3d Cir. 2014). Here, the language, context , and structur e of § 1415 lead inexorably to one conclusion: § 1415(b)(6)(B ) was intended to reflect the sam e statute of limitations set forth in § 1415(f)(3)(C) . To the extent that some of its language appears to conflict with that conclusion, the legislative history confirms what is apparent from our analysis of the statute itself. That is, the inconsistent language reflects nothing more than a drafting error in the reconciliation process, turning a Case: 14-1387 Document: 003112081189 Page: 49 Date Filed: 09/22/2015 50 passage that was at each stage of the legislative process thought to be a statute of limitations into s omething that both contravenes c ongressional intent and re nders the statute illogical. Thus, the IDEA “needs common sense revision ,” Morgan , 466 F.3d at 279, reflectin g c ongressional intent that a due process complaint must be presented “within 2 years” of a parent’s reasonable discovery date, not that remedies be limited to injuries that occurred “not more than 2 years before” that date. The upshot of all this is two -fold. On the one hand, although a child’s right to special education under the IDEA does not turn on parental vigilance, M.C. , 81 F.3d at 397, pa rental vigilance is vital to the preservation and enforcement of that right . A s we made clear i n D.K., claims that are known or reasonably sh ould be known to parents must be brought withi n two years of that “knew or should have known” date , and parents ma y not, without satisfying one of the two statutory exceptions , knowingly sit on their rights or attempt to sweep both timely and expired claims in to a single “continuing violation” claim brought years later . 696 F.3d at 248 . Parents are often in a positi on to be forceful advocates for their children and through their vigilance and perseverance to help fulfill the IDEA’s promise of a free appropriate public education. That “cooperative process . . . between parents and schools” that results from a parent’ s action , after all, is at the very “core of the statute” itself. Schaffer , 546 U.S. at 53. Thus the sooner parents start that process and secure appropriate intervention and remedial supports after they discover or reasonably should have discovered the need for it , the better for the well -being of the child, the goals of the school district , and the relationship between the family and school administrators . Case: 14-1387 Document: 003112081189 Page: 50 Date Filed: 09/22/2015 51 On the other hand, where parents neither kn ew nor reasonably should have know n of the special n eeds of their child or of the educational system’s failure to respo nd appropriately to those needs , the other partner in this endeavor — the school district itself — still has its independent duty to identify those needs within a reasonable time period and to work with the parents and the IEP team to expeditiously design and implement an appropriate program of remedial support . 20 U.S.C. § 1412(a)(3) ; see also Forest Grove , 557 U.S. at 245; P.P. , 585 F.3d at 738. This is a profound responsibility, with the po wer to change the trajectory of a child’s life . Thus, the corollary to D.K. is that when a school district has failed in that responsibility and parents have taken appropriate and timely action under the IDEA , then that child is entitled to be made whole with nothing less than a “complete” remedy. Forest Grove , 557 U.S. at 244. Compensatory education is crucial to achieve that goal, and the courts, in the exercise of their broad discretion, may award it to whatever extent necessary to make up for the chi ld’s lost progress and to restore the child to the educational path he or she would have travel ed but for the deprivation. See D.F. , 694 F.3d at 498 -99. In this way, the courts too have an essential function in fulfilling Congress’s mandate in the IDEA a nd enabling each child with special needs to reach his or her full potential. For these reasons, w e hold today that , absent one of the two statutory exceptions found in § 1415(f)(3)(D) , parents have two years from the date they knew or should have known of the violation to request a due process hearing through the filing of an administrative complaint a nd that, assuming parents timely file that complaint and liability is proven , Congress did not abrog ate our longstanding precedent Case: 14-1387 Document: 003112081189 Page: 51 Date Filed: 09/22/2015 52 that “a disabled child i s entitled to compensatory education for a period equal to the period of deprivation, but excluding the time reasonably required for the school district to rectify the problem.” D.F. , 694 F.3d at 499 (quoting M.C. , 81 F.3d at 397). * * * G.L.’s claim was filed within two years of the date his parents knew or reasonably should have known of his injury , and thus his right to compensatory education upon proof of a violation was not curtailed by the IDEA’s statute of limitations . Accordingly, w e will affi rm the District Court’s decision that his claims for remedy prior to March 2010 were not time -barred and will remand to the District Court for pr oceedings consistent with this O pinion. Case: 14-1387 Document: 003112081189 Page: 52 Date Filed: 09/22/2015
Addresses two-year statute of limitations for filing due process hearings under IDEA including references to G.L. v. Ligonier Valley School District Authority.
Attachments provided to OSEP from the Office of General Council (OGC):
- G.L.; Mr. G.L., Mrs. E.L., in their own right v. Ligonier Valley School District Authority, Appellant
- G.L., Mr. G.L., Mrs. E.L. v. Ligonier Valley School District Authority, No. 14-1387, Amicus Curiae Letter Brief
Last modified on October 24, 2023