J. R. v. Ventura Unified School District

── J. R. v. Ventura Unified School District ── Court: Court of Appeals for the Ninth Circuit Date: April 22, 2026 Category: General FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT J. R., a minor, by and through his Nos. 25-334 & mother, Mary Perez, 25-5247 D.C. No. Plaintiff - Appellee, 2:22-cv-02717- HDV-MAR v. VENTURA UNIFIED SCHOOL DISTRICT, OPINION Defendant - Appellant. Appeal from the United States District Court for the Central District of California Hernan Diego Vera, District Judge, Presiding Argued and Submitted October 6, 2025 San Francisco, California Filed April 22, 2026 Before: Jacqueline H. Nguyen and Daniel A. Bress, Circuit Judges, and Richard D. Bennett, District Judge.* Opinion by Judge Bress * The Honorable Richard D. Bennett, United States District Judge for the District of Maryland, sitting by designation. 2 J.R. V. VENTURA UNIFIED SCHOOL DISTRICT SUMMARY** Individuals with Disabilities Education Act Reversing the district court’s judgment, the panel held that a lawsuit brought by parents against the Ventura Unified School District under the Individuals with Disabilities Education Act (IDEA) was untimely as to educational services their child received before 2019. As a preliminary matter, the panel held that the district court’s judgment—which fully resolved the merits and left only the question of attorneys’ fees pending—was final and appealable for purposes of 28 U.S.C. § 1291. The parents challenged the school district’s alleged failure to assess their child for autism. They did not sue until the child was diagnosed with autism in 2021, but they sought relief from the school district for allegedly inadequate education going back to 2012. The panel held that the parents’ IDEA suit was untimely as to educational services received prior to 2019. The IDEA requires that parents must challenge their child’s allegedly inadequate special education within two years of the date the parents “knew or should have known about the alleged action that forms the basis of the complaint.” 20 U.S.C. § 1415(f)(3)(C). This statute of limitations sets forth a discovery rule, providing that actual or constructive knowledge is sufficient to start the limitations period. The panel held that for an IDEA claim alleging that a school ** This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader.  J.R. V. VENTURA UNIFIED SCHOOL DISTRICT 3 district’s failure to assess and diagnose a student has resulted in the alleged denial of a free appropriate public education (FAPE), the statute of limitations begins to run when parents know or should know (1) the fact of the school district’s action or inaction (i.e., the failure to assess and diagnose), and (2) that their child is being denied a FAPE (i.e., the child’s education is inadequate). Here, because the parents knew the school district had not assessed their child for autism and had sufficient reason to believe his education was chronically inadequate, their claims predating the limitations period were time-barred. Adopting the Third Circuit’s analysis, the panel found inapplicable an exception to the two-year limitations period based on misrepresentations by the local educational agency that it had resolved the problem forming the basis of the complaint. The panel also found inapplicable an exception based on withholding of required information from a parent. Accordingly, the panel reversed the district court’s judgment awarding benefits for the 2012-2019 period, vacated the district court’s