California OAH special education order · January 12, 2026
Order Denying Motion to Compel
OAH Case No. 2025120840 · ALJ Alexa Hohensee
OAH denied Student's motion to compel Sweetwater to produce native-format Infinite Campus records and metadata, finding no authority requires metadata and Parent already had complete PDF copies of the educational record.
This case went to decision
Sweetwater Union High School District v. Student: Sweetwater Union may implement its 2025 IEP and conduct a mental health assessment without parental consent. (2026)
Summary
In a due process case Sweetwater filed over its April 2025 IEP and its assessment plans, Student moved to compel Sweetwater to produce Student's records in native electronic format, including metadata, audit trails, and contact logs from its Infinite Campus system, to check their authenticity. Sweetwater opposed, showing through its Director of Special Services' declaration that Parent had received a complete copy of the educational file and that Sweetwater does not keep SEIS metadata as part of student records. OAH denied the motion. It found that neither the Education Code nor the IDEA requires metadata or native files, that PDF copies did not keep Parent from inspecting and reviewing the records, and that Student had not shown why metadata was relevant to defending against Sweetwater's claims.
Why it matters
Parents' records rights under Education Code section 56504 and the IDEA generally cover copies of the records themselves, not native files or metadata, unless the parent can show the metadata is relevant and necessary. Concerns about when or by whom a document was created can instead be raised by questioning witnesses at hearing.
Key authority cited
- Ed. Code, § 56504
- Ed. Code, § 49061
- 20 U.S.C. § 1232g(a)(4)(A)
- 20 U.S.C. § 1415(b)(1)
- 34 C.F.R. § 300.613(b)
- 34 C.F.R. § 99.3
People named in the order
- Alexa Hohensee, Administrative Law Judge
Topics
Full text of the order
Published text of the OAH order. Page headers and numbers from the original PDF have been dropped.
BEFORE THE
OFFICE OF ADMINISTRATIVE HEARINGS
STATE OF CALIFORNIA
IN THE MATTER OF:
SWEETWATER UNION HIGH SCHOOL DISTRICT,
v.
PARENT ON BEHALF OF STUDENT.
OAH CASE NUMBER 2025120840
ORDER DENYING MOTION TO COMPEL
JANUARY 12, 2026
On December 19, 2025, Sweetwater Union High School District, called Sweetwater, filed a request for due process naming Parent on behalf of Student. On January 9, 2026, an order granting a continuance in this matter was granted scheduling the case for hearing on January 21 and 22, 2026.
On January 5, 2026, Student filed a motion to compel Sweetwater to produce a copy of Student’s educational record:
in its native electronic format, specifically including all data fields, contact logs, audit trails, and metadata contained within {Sweetwater’s] “Infinite Campus” Student Information System.
Student’s motion is supported by the sworn declaration of Parent, and concedes that in response to Parent’s August 25, 2025 request, Parent has received copies of Student’s education record in PDF format and reviewed Student’s information at Sweetwater’s office onscreen. However, Student seeks metadata such a creation dates and author identifications for electronically produced documents and entries to verify their authenticity. Student argues Education Code section 56504, entitles parents to copies of school records, and asserts a right to digital records of Student wherever they are maintained and in whatever format they are maintained.
Sweetwater’s opposition notes that parents are entitled to examine all school records of his or her child and to receive copies within five business days after the request is made. (Ed. Code, § 56504.) An education record is any item of information directly related to an identifiable pupil that is maintained by the educational agency or by a person acting for the agency. (20 U.S.C. § 1232g(a)(4)(A); see Ed. Code, § 49061.)
Sweetwater argues the Education Code does not provide that Parents are entitled to “native” records or metadata associated with electronic records or databases.
Education records under the IDEA are defined by the federal Family Educational Rights and Privacy Act. (20 U.S.C. § 1232; 34 C.F.R. § 99.3.) Education records include records, files, documents, and other materials containing information directly related to a student, other than directory information, which are maintained by an educational agency or institution or by a person acting for such agency or institution. (20 U.S.C.
§ 1232g(a)(4)(A); Ed. Code, § 49061, subd. (b).) Pupil or education records maintained by a school district employee in the performance of his or her duties include those recorded by handwriting, print, tapes, film, microfilm or other means. (Ed. Code, §§ 49061, 56504.)
To guarantee parents the ability to make informed decisions about their child’s education, the IDEA grants parents of a child with a disability the right to examine all relevant records relating to their child’s identification, evaluation and educational placement. (20 U.S.C. §1415(b)(1).) School districts must permit parents to inspect and review any education records relating to their children that are collected, maintained, or used by the agency under this part. The right to inspect and review education records under this section includes the right to a response from the participating agency to reasonable requests for explanations and interpretations of the records. It also includes the right to request that the agency provide copies of the records containing the information if failure to provide those copies would effectively prevent the parent from exercising the right to inspect and review the records. (See 34 C.F.R. §300.613(b).)
The sworn declaration of Sweetwater’s Director of Special Services establishes that Parent has received a complete copy of his educational file, including copies of his special education file, the school cumulative file, the Special Education Information System, called SEIS, contact log, occupational therapy notes, speech minutes calendar, speech treatment notes, and speech assessment report. The Director explained that Sweetwater does not maintain metadata from SEIS entries as part of students’ educational records.
Student cites no authority requiring Sweetwater to provide, in addition to complete copies of all documents and entries in Student’s educational record, the meta data for those records. Parent on behalf of Student will have an opportunity to question witnesses concerning the creation and authenticity of documents offered into evidence at hearing. Receipt of PDF copies of Student’s educational records does not effectively prevent Parent from exercising the right to inspect and review those records.
In this specific instance, Sweetwater has requested a due process hearing to determine if its April 2025 individualized education program, called IEP, offered Student a free appropriate public education, and whether Sweetwater may conduct assessments of Student pursuant to February and June 2025 assessment plans. Sweetwater will need to prove that the IEP, amendments, and assessment plans at issue were made in writing and given to Parent. This can be done with PDFs, proofs of mailing, and the testimony of witnesses. Student possesses complete PDF copies of his educational record, and has made no showing why the metadata in any of these records, or others, is relevant or necessary to Student’s defense against Sweetwater’s claims.
Student’s motion to compel production of native infinite campus records and metadata is denied.
IT IS SO ORDERED.
Alexa Hohensee Administrative Law Judge Office of Administrative Hearings