Court ruling clarified authority of hearing officers and responsibilities of local education agencies
Why is Prince William County School Board v. Lassiter important?
Judge Rossie D Alston, Jr., issued a ruling in Prince William County School Board v. Lassiter 13 November 2025 that provided clarification on the authority of special education hearing officers and the responsibilities of school districts during due process appeals. The decision affirmed hearing officers may order private school placement when it is necessary to provide Free Appropriate Public Education (Individuals with Disabilities Education Act, 2004). Judge Alston’s ruling also underscored the expectation that districts accurately interpret, respond to, and litigate the issues raised in due process proceedings.
The case and findings
Prince William County School Board v. Lassiter (2025) involved a student identified as having attention-deficit-hyperactivity disorder, anxiety, chronic pain, visual disorders, and auditory-memory deficits. After challenges in securing support under Section 504 and later under IDEA, the student’s parents placed her in a private college-preparatory school and pursued due process. The hearing officer ruled in favor of the parents, finding the local education agency had not provided FAPE and ordering the division to fund the private placement. Legal decisions in which parents prevail remain relatively rare in Virginia, making this outcome notable.
The Prince William LEA appealed the decision. In reviewing the record, the court found the LEA’s appeal did not connect the arguments raised in its original complaint seeking relief in its later motion. Judge Alston described the filing as “untethered” from the claims initially brought forward and noted the LEA did not substantiate its assertion that the hearing officer had ordered a multi-year placement without annual review. The court clarified the hearing officer’s decision explicitly situated the private school placement within the standard annual IEP review process, consistent with IDEA requirements.
Prince William County School Board v. Lassiter (2025) delivers a reminder of two legal concepts: (a) hearing officers have full authority under IDEA to order a private placement when an LEA) fails to provide FAPE, and (b) school districts must actually litigate the issues they raise. Judge Alston upheld the hearing officer’s decision and criticized the LEA’s appeal as “untethered” from its own complaint and unsupported by the record.
In his ruling, Judge Alston confirmed that a private school placement ordered by a hearing officer is still subject to the standard annual IEP review process; nothing in the decision created a multi-year mandate. Judge Alston also reaffirmed private schools do not need to be approved by the SEA to qualify as “appropriate” placements. The ruling is fully consistent with longstanding federal guidance. In its “Letter to Eig,” the US Office of Special Education Programs (1990) stated that district approval or state approval is not required for reimbursement. The holding also aligns with Supreme Court precedent, including Florence County School District Four v. Carter (1993) and Forest Grove School District v. T. A. (2009), both of which held that reimbursement may be awarded even when the private school lacks state approval or provides instruction that does not meet all state standards.
Key Takeaways
Hearing officers retain the authority to order private placement when warranted by the evidence.
Such placements remain subject to annual IEP review; they are not automatically multi-year decisions.
LEAs must ensure that appeals accurately address the issues raised in their complaints and are supported by the record.
The ruling reinforces that procedural accuracy and clear reasoning are essential in IDEA dispute-resolution processes.
Judge Alton’s decision serves as a reminder of the standards governing IDEA litigation and the importance of careful, accurate engagement at each stage.
References
Florence County School District Four v. Carter, 510 U.S. 7 (1993).
Forest Grove School District v. T.A., 557 U.S. 230 (2009).
Individuals with Disabilities Education Act. (2004). Pub. L. No. 108-446, 118 Stat. 2647.
Office of Special Education Programs. (1990). Letter to Eig. U.S. Department of Education.
Prince William County School Board v. Lassiter, No. 1:24-cv-00610 (E.D. Va. Nov. 13, 2025).