Laboratory Charter School v. M. S.

── Laboratory Charter School v. M. S. ── Court: Court of Appeals for the Third Circuit Date: April 21, 2026 Category: General U.S. COURT OF APPEALS FOR THE THIRD CIRCUIT No. 25-2173 LABORATORY CHARTER SCHOOL, Appellant v. M.R.S., BY AND THROUGH HER PARENT SHARONA SMITH; SHARON SMITH, INDIVIDUALLY _____________________________ Appeal from the U.S. District Court, E.D. Pa. Judge Juan R. Sánchez, No. 2:21-cv-05538 Before: PORTER, MONTGOMERY-REEVES, and BOVE, Circuit Judges Submitted Apr. 8, 2026; Decided Apr. 21, 2026 _____________________________ NONPRECEDENTIAL OPINION * MONTGOMERY-REEVES, Circuit Judge. In this appeal under the Individuals with Disabilities Education Act (“IDEA”), Laboratory Charter School (“Lab Charter”) seeks reversal of a District Court’s order holding that Lab Charter denied M.R.S., a disabled minor, a Free Appropriate Public Education (“FAPE”) for her sixth-grade year, and award- ing M.R.S. partial compensatory education. We agree with the District Court’s conclu- sions, so we will affirm the District Court’s judgment. 1 * This disposition is not an opinion of the full Court and, under I.O.P. 5.7, is not binding precedent. 1 The District Court had jurisdiction under 20 U.S.C. § 1415(i)(3)(A) and 28 U.S.C. § 1331. We exercise jurisdiction under 28 U.S.C. § 1291.  First, the District Court did not commit reversible error in finding that Lab Charter denied a FAPE to M.R.S. in her sixth-grade year. 2 The District Court found that Lab Char- ter failed to reevaluate M.R.S. for a new Individualized Education Program (“IEP”) by April 4, 2020—even though the IDEA mandated this reevaluation. See 20 U.S.C. § 1414(a)(2)(B)(ii) (requiring, at minimum, triennial reevaluations); Ridley Sch. Dist. v. M.R., 680 F.3d 260, 269 (3d Cir. 2012) (“The IEP is . . . the primary mechanism for deliv- ering a FAPE.” (citation and quotation marks omitted)). What is more, the District Court noted that an independent evaluation of M.R.S. revealed that the IEP Lab Charter eventu- ally put in place was insufficient. 3 Our own review of that evaluation reveals that M.R.S. suffered from several mental-health issues, including “[s]ignificant symptoms of depres- sion,” “[s]ignificant variability on cognitive ability testing,” “[s]ignificant problems on tasks of executive functioning,” and “[s]ignificant academic weaknesses across reading, writing and math.” Joint Appendix (hereinafter “App. __”) 710. And if those difficulties 2 Whether Lab Charter fulfilled its FAPE obligations is a question “subject to clear error review as [a] question[] of fact.” P.P. ex rel. Michael P. v. W. Chester Area Sch. Dist., 585 F.3d 727, 735 (3d Cir. 2009). That highly deferential standard demands our adherence to the District Court’s factual findings unless those findings are not “plausible in light of the record viewed in its entirety.” Anderson v. City of Bessemer City, 470 U.S. 564, 573–74 (1985). 3 Lab Charter assails the District Court for failing to accept the state administrative officer’s credibility determinations as to this independent evaluation. But our law does not require unbridled deference to state agencies. See S.H. v. State-Operated Sch. Dist. of Newark, 336 F.3d 260, 270 (3d Cir. 2003) (“Factual findings from the administrative proceedings are to be considered prima facie correct. If a reviewing court fails to adhere to them, it is obliged to explain why.” (citation modified)). Here, the District Court explained why it departed from the officer’s determinations. And the officer did not make credibility find- ings because, as M.R.S. points out, the author of the evaluation did not testify. 2 did not put Lab Charte