S.B. v. Idaho State Board of Education, et al.,

MEMORANDUM DECISION AND ORDER - 1
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF IDAHO
S.B., Parent of a child with a disability,
Plaintiff,
v.
IDAHO STATE BOARD OF
EDUCATION; IDAHO DEPARTMENT
OF EDUCATION,
Defendants.
Case No. 1:25-cv-00183-DCN
MEMORANDUM DECISION AND
ORDER
I. INTRODUCTION
Before the Court is Defendants Idaho State Department of Education (“ISDE”) and
Idaho State Board of Education’s (“ISBE”) motion to dismiss. Dkt. 7. Plaintiff S.B., Parent
of a child with a disability, responded (Dkt. 12) and ISDE and ISBE replied (Dkt. 14).
Having reviewed the record and briefs, the Court finds that the facts and legal
arguments are adequately presented. Accordingly, in the interest of avoiding further delay,
and because the Court finds the decisional process would not be significantly aided by oral
argument, the Court will address the motion without oral argument. Dist. Idaho Loc. Civ.
R. 7.1(d)(1)(B). For the reasons outlined below, the Court finds good cause to dismiss this
matter entirely because the case is moot.
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II. BACKGROUND
This case is brought pursuant to 20 U.S.C. § 1415(i)(2)(A), a section of the
Individuals with Disabilities Act (“IDEA”) which allows civil actions to be brought in
federal district court when a party has been aggrieved by a decision made during a due
process hearing conducted in accordance with IDEA.
S.B. is the parent of D.H., a disabled individual. D.H. is a high school student that
lives and attends school within the Buhl Joint School District (the “District”) in Idaho. In
2024, D.H. was trespassed from school and placed on an at home educational plan which
S.B. felt denied D.H. his right to Free Adequate Public Education (“FAPE”), as required
under IDEA. In order for D.H. to obtain FAPE, S.B. asked the District to provide an
independent educational evaluation at public expense so that better accommodations could
be provided for D.H. which allowed him FAPE.
Viewing the District’s response as unsatisfactory, S.B. brought a complaint pursuant
to IDEA (the “IDEA Complaint”) against the District and the ISDE which triggered a due
process hearing1 overseen by a third-party hearing officer. During the due process hearing,
S.B. and the District reached a settlement agreement disposing of the District as a party to
the due process hearing. Subsequently, the ISDE moved to be dismissed as a defendant,
and the motion was granted by the hearing officer.
On March 28, 2025, S.B. filed the instant federal lawsuit under IDEA and 20 U.S.C.
§ 1415(i)(2) as a quasi-appeal of the hearing officer’s orders. Dkt. 1. S.B.’s causes of action
1 “Due process hearing” is the term used for the entirety of the proceedings stemming from the IDEA
Complaint. It is not limited to the actual hearing itself.
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are styled as “Errors” of the hearing officer’s various orders. Id. at 10, 12, 13. And S.B.’s
prayer for relief asks the Court to “Evaluate” the hearing officer’s decisions, declare S.B
the prevailing party, and award fees and costs. Id. at 16.
ISDE and ISBE have moved to dismiss for various reasons. Dkt. 7.
III. LEGAL STANDARD
Federal Rule of Civil Procedure 12(b)(1) allows a party to move to dismiss claims
for lack of subject matter jurisdiction. Fed R. Civ. P. 12(b)(1). The objection that a federal
court lacks subject matter jurisdiction may be raised by a party, or by a court on its own
initiative, at any stage in the litigation, even after trial and the entry of judgment. Arbaugh
v. Y&H Corp., 546 U.S. 500, 506 (2006).
“Dismissal for lack of jurisdiction is not warranted to the extent that the complaint
pleads facts from which federal jurisdiction clearly may be inferred.” Demarest v. United
States, 718 F.2d 964, 965 (9th Cir. 1983). A Rule 12(b)(1) jurisdictional attack may be
facial or factual. White v. Lee, 227 F.3d 1214, 1242 (9th Cir. 2000). “In a facial attack, the
challenger asserts that the allegations contained in a complaint are insufficient on their face
to invoke federal jurisdiction.” Safe Air for Everyone v. Meyer, 373 F.3d 1035, 1039 (9th
Cir. 2004).
“Article III, § 2, of the Constitution limits the jurisdiction of federal courts to ‘Cases’
and ‘Controversies,’ which restricts the authority of federal courts to resolving the legal
rights of litigants in actual controversies. To invoke federal-court jurisdiction, a plaintiff
must demonstrate that he possesses a legally cognizable interest, or personal stake, in the
outcome of the action. This requirement ensures that the Federal Judiciary confines itself
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to its constitutionally limited role of adjudicating actual and concrete disputes, the
resolutions 	of 	which 	have 	direct 	consequences 	on 	the 	parties 	involved.” 	Genesis
Healthcare Corp. v. Symczyk, 569 U.S. 66, 71 (2013) (citation modified).
IV. DISCUSSION
A. The Court lacks jurisdiction in this case because there is no live case or
controversy for which relief can be granted.
Congress saw fit to ensure that all students in this country have access to a FAPE
when they enacted IDEA. 20 U.S.C. § 1400 et. seq. IDEA provides that state and local
educational agencies may receive federal funding for taking over the responsibility of
providing a FAPE to its students. 20 U.S.C. §§ 1412-13. To ensure that the states are
adequately providing a FAPE to its students, IDEA sets up procedural safeguards in 20
U.S.C. § 1415.
For example, under IDEA, there must be “[a]n opportunity for any party to present
a complaint 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 . . . .” 20 U.S.C. § 1415(b)(6)(A). Under this section, “the parents or the local
educational agency involved in such complaint shall have an opportunity for an impartial
due process hearing . . . .” Id. at §1415(f)(1)(A). At the due process hearing, “a decision
made by a hearing officer shall be made on substantive grounds based on a determination
of whether the child received a free appropriate public education.” Id. at §1415(f)(3)(E)(i).
Once the hearing has been conducted, “[a]ny party aggrieved by the findings and decision
made under subsection (f) . . . shall have the right to bring a civil action with respect to the
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complaint presented pursuant to this section, which action may be brought in . . . a district
court of the United States . . . .” Id. at §1415(i)(2)(A).
In the present case, S.B. originally asked for the District to perform an independent
educational evaluation; the District never replied to the request. S.B. then asked for help
from the ISDE because the District failed to provide D.H. with a FAPE by trespassing him
from school and refusing to work with S.B. to provide an independent educational
evaluation.
After receiving no response to this request, S.B. brought a complaint pursuant to
IDEA for the purpose of obtaining a FAPE for D.H. The IDEA Complaint named both the
District and the ISDE as parties. Approximately five weeks after the IDEA Complaint was
filed, S.B. and the District entered a settlement agreement which, it appears from all
evidence in the record, adequately addressed the educational needs of D.H.2 Around the
same time, the ISDE filed a Motion to Dismiss for being an improper party and because
S.B. failed to state a claim for which relief could be granted. This motion was granted by
the hearing officer after arguments were presented by all parties. Nothing in the record
provided to the Court suggests that the due process safeguards provided by 20 U.S.C. §
1415 were subverted in this instance.
The granting of the motion to dismiss in the due process hearing is ultimately the
2 The settlement agreement was never made part of the administrative record (Dkt. 1-3, at 4), and S.B. does
not allege any deficiencies or dissatisfaction with the settlement agreement in the Complaint. See Dkt. 1.
Only after the issue of mootness was raised by Defendants ISDE and ISBE did S.B. allege the settlement
gave “incomplete relief.” Dkt. 7-1, at 10; Dkt. 12, at 12. However, S.B. does no more than state the relief
is incomplete and does not provide any suggestion as to why that is or how the relief could be more
expansive. See Dkt. 12, at 12.
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decision which aggrieved S.B.,3 triggering the civil suit provision in 20 U.S.C. §
1415(i)(2)(A). The main problem with this case, which is correctly identified in ISDE and
ISBE’s memoranda in support of their Motion to Dismiss, is that there is no further relief
that can be granted by the Court that will provide a FAPE to D.H.
The settlement agreement executed between S.B. and the District resolved the
educational issues which triggered S.B. to bring the IDEA Complaint in the first place and
D.H. is now receiving a FAPE as mandated by IDEA. Therefore, it is difficult to say S.B.
was “aggrieved” by the hearing process to the extent she needed to file a federal cause of
action 	when 	she 	ultimately 	received 	the 	relief 	she 	had 	sought. 	See 	20 	U.S.C.
§1415(i)(2)(A).
Even if the Court did find in S.B.’s favor and held the hearing officer improperly
granted ISDE’s motion to dismiss from the due process hearing, S.B. has not indicated
what relief ISDE or ISBE would be able to provide because, again, D.H. is receiving a
FAPE per the settlement agreement with the District.
Even in S.B.’s current Complaint, the only relief requested is that the Court declare
the decisions on the motions in the due process hearing incorrect, declare the ISDE
responsible as a State Educational Agency for ensuring a FAPE to all students in Idaho,
declare S.B. the prevailing party, 4 and award attorneys’ fees. Dkt. 1, at 16. But these
requests have nothing to do with D.H. receiving a FAPE as mandated by the IDEA.
3 S.B. does raise grievances about other minor decisions made by the hearing officer prior to the motion to
dismiss, but they do not affect the outcome of this decision.
4 It is not clear whether S.B. is asking the Court to declare her the prevailing party in this case or in the due
process hearing below. Regardless, the Court finds it improper to make such a finding because, as outlined
above, there is no active case or controversy.
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Moreover, from the evidence presented by S.B., the due process hearing awarded the
procedural due process required under the IDEA.5 Therefore, S.B. does not have a legally
cognizable interest, or personal stake, in the outcome of this action because there is nothing
more to adjudicate. The case is moot.
V. CONCLUSION
After reviewing the briefing and the portions of the administrative record provided
by all parties, the Court is satisfied that the procedural due process required under IDEA
was afforded to S.B. at the hearing level. Moreover, S.B. has not identified a legally
cognizable personal interest in her cause of action and there is no more relief that can or
should be granted. Therefore, the ISDE and ISBE’s Motion to Dismiss is granted because
the case is moot. As it does not appear likely that any amendment could save the claims,
the Court will not grant S.B. leave to amend. See Foman v. Davis, 371 U.S. 178, 182 (1962)
(ruling leave to amend need not be granted if amendment would be futile).
VI. ORDER
1. 	The Idaho State Department of Education and the Idaho State Board of Education’s
Motion to Dismiss (Dkt. 7) is GRANTED with prejudice based on the grounds that
the Court lacks jurisdiction due to the case being moot.
5 Even were the Court to independently review the hearing officer’s actions—disregarding the mootness
problem—it would find no error. The concepts of due process do not mandate a specific result, only that a
party has an opportunity to be fairly heard. S.B. clearly had that in this circumstance. She engaged in the
process and was afforded adequate due process. Based upon the record, the Court cannot say S.B. was
refused any fair process or that the hearing officer’s decisions should be subject to reversal. See U.S. v.
Salerno, 481 U.S. 739, 746 (1987) (explaining that, to plead a substantive due process claim, a plaintiff
must allege facts showing the Defendants “engag[ed] in conduct that shocks the conscience or interferes
with the implicit concept of ordered liberty”) (citation modified).
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2. 	This case is CLOSED.
DATED: February 18, 2026
_________________________
David C. Nye
U.S. District Court Judge
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