California OAH special education order · May 12, 2026
Order Determining Due Process Complaint Insufficient
OAH Case No. 2026050400 · ALJ June Lehrman
OAH found Student's complaint insufficient because it alleged harassment, unsafe conditions, and a hostile environment at Castaic High without any supporting facts, and gave Student 14 days to amend.
Summary
William S. Hart Union High School District filed a notice of insufficiency the same day Student filed a due process complaint. The complaint alleged ongoing harassment, unsafe conditions, and a hostile and abusive environment at Castaic High, and said staff had harassed, intimidated, or mistreated Student. OAH found the complaint insufficient because it gave no factual details about what happened, so the district could not tell what the problem was or how to prepare. Student may file an amended complaint within 14 days, or the case will be dismissed, and all previously set dates were vacated.
Why it matters
Labels like "harassment" or "unsafe environment" are not enough. A complaint must describe specific facts, such as what happened, when, and who was involved, and tie them to the student's special education. Parents without a lawyer can ask OAH for a mediator to help them identify their issues and proposed resolutions before amending.
Key authority cited
- 20 U.S.C. § 1415(b)(7)(A)
- 20 U.S.C. § 1415(c)(2)(D)
- 20 U.S.C. § 1415(c)(2)(E)(i)(II)
- Ed. Code, § 56505
- Escambia County Bd. of Educ. v. Benton (S.D.Ala. 2005) 406 F.Supp.2d 1248
- 71 Fed. Reg. 46,540-46541, 46699
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:
PARENTS ON BEHALF OF STUDENT,
v.
WILLIAM S. HART UNION HIGH SCHOOL DISTRICT.
OAH CASE NUMBER 2026050400
ORDER DETERMINING DUE PROCESS COMPLAINT
INSUFFICIENT
MAY 12, 2026
On May 11, 2026, Student filed a Due Process Hearing Request, called a complaint, with the Office of Administrative Hearings, referred to as OAH, naming William S. Hart Union High School District. On May 11, 2026, William S. Hart filed a Notice of Insufficiency as to the complaint.
APPLICABLE LAW
The named parties have the right to challenge the complaint’s sufficiency.
(20 U.S.C. § 1415(b) & (c).) The party filing the complaint is not entitled to a hearing unless the complaint meets the requirements of title 20 United States Code section 1415(b)(7)(A).
A complaint is sufficient if it: (1) describes the problem relating to the proposed change regarding the Student’s identification, evaluation, or educational placement, or providing the Student a free appropriate public education; (2) includes facts about the problem; and (3) includes a proposed resolution to the extent known and available to the party at the time. (20 U.S.C. § 1415(b)(7)(A)(ii)(III) & (IV).) These requirements prevent vague and confusing complaints, and promote fairness by providing the named parties with sufficient information to know how to prepare for the hearing and how to participate in resolution sessions and mediation. (See H.R. Rep. No. 108-77, 1st Sess.
(2003), p. 115; Sen. Rep. No. 108-185, 1st Sess. (2003), pp. 34-35.)
The complaint provides enough information when it provides “an awareness and understanding of the issues forming the basis of the complaint.” (Sen. Rep. No. 108- 185, supra, at p. 34.) The pleading requirements should be liberally construed in light of the broad remedial purposes of the IDEA and the relative informality of the due process hearings it authorizes. (Alexandra R. ex rel. Burke v. Brookline School Dist. (D.N.H., Sept. 10, 2009, CIV. 06-CV-0215-JL) 2009 WL 2957991[nonpub. opn.]; Escambia County Bd. Of Educ. v. Benton (S.D.Ala. 2005) 406 F.Supp.2d 1248, 1259-1260; Sammons v. Polk County School Bd. (M.D.Fla., Oct. 28, 2005, 8:04CV2657T24EAJ) 2005 WL 2850076 [nonpub. opn.]; Cf. M.S.-G v. Lenape Regional High School Dist. Bd. of Educ. (3d Cir.
2009) 306 Fed.Appx. 772, 775 [nonpub. opn.].) Whether the complaint is sufficient is a matter within the sound discretion of the Administrative Law Judge. (Assistance to States for the Educ. of Children with Disabilities & Preschool Grants for Children with Disabilities (Aug. 14, 2006) 71 Fed. Reg. 46,540-46541, 46699.)
DISCUSSION
Student’s complaint alleges that William S. Hart has engaged in “ongoing harassment and unsafe conditions on campus.” The complaint further alleges that the high school Student attends, Castaic High, is the “most disgusting school,” and is an “unsafe, hostile, and abusive environment.” Student’s complaint further alleges that staff have “harassed, intimidated, or mistreated Student.” The complaint does not include any factual allegations. William S. Hart is entitled to be notified of the facts about the problem. Thus, the complaint fails to provide William S. Hart with the required problem description and the facts relating to the problem. Student provides no details concerning the alleged harassment and unsafe conditions, nor the hostile or abusive environment. Student has failed to state sufficient facts supporting this claim, and the claim is insufficient.
A parent without an attorney may request that OAH provide a mediator to assist the parent in identifying the issues and proposed resolutions that must be included in a complaint. (Ed. Code, § 56505.) Parents are encouraged to contact OAH for assistance if they intend to amend their due process hearing request.
ORDER
1. Student’s complaint is insufficiently pled under section title 20 United States
Code 1415(c)(2)(D).
2. Student’s shall be permitted to file an amended complaint under title 20
United States Code section 1415(c)(2)(E)(i)(II).
3. The amended complaint shall comply with the requirements of title 20 U.S.C.
section 1415(b)(7)(A)(ii), and shall be filed and served on the attorney for William S. Hart not later than 14 days at 5:00 PM from the date of this order.
4. If Student fails to file a timely amended complaint, the complaint will be
dismissed.
5. All dates previously set in this matter are vacated.
IT IS SO ORDERED.
June Lehrman Administrative Law Judge Office of Administrative Hearings