Parent and student fall short of proving link between student’s physical altercation and autism diagnosis

A 17-year-old student and his mother sought a hearing under the Individuals with Disabilities and Education Act (IDEA) after the school district’s manifestation-determination review concluded that a physical altercation with a classmate was not a result of the student’s disability. After reviewing the procedure used in the manifestation review, the Court affirmed the school district’s determination.  Specifically, the Court found insufficient evidence to show a causal connection between the behavior in question and the student’s diagnosis of Autism Spectrum Disorder.  The student and mother also failed to show how the student’s conduct directly resulted from the district’s purported failure to follow the Individualized Education Plan.