Court finds insufficient evidence linking student’s alleged mood disorder to violent episodes

A high school student and her parent sought to overturn the results of a manifestation-determination review, which had concluded that the student’s incidences of physical violence against a peer and a teacher were not a result of her disabilities. The Court denied the student and parent’s request for relief.  Despite the parent maintaining that the student had a mood disorder that could cause physical outbursts, the Court concluded that insufficient evidence was presented to demonstrate that the district had documentation or knowledge of that disorder.  The student and parent also did not present any evidence showing a causal relationship between that particular diagnosis and the conduct at issue.