In this episode of our podcast, host Sloan Simmons engages with Lozano Smith special education experts Aly Bivins and Josh Walden.  They discuss the recent trends and guidance in the arena of goal writing for special education students.  Aly and Josh provide insights on recent OAH decisions on point, and lessons learned from those due process outcomes.

Show Notes & References

• 1:17 – Lozano Smith Podcast Episode 66 – Addressing Inclusion Confusion Following COVID (Listen here)


• 2:06 – The importance of annual goals (D.R. v. Redondo Beach Unified School District (9th Cir. 2022) 56 F.4th 636) (Client News Brief 15 – April 2023)


• 3:06 – Impact on Rachel H. decision (Sacramento City Unified School District v. Rachel H. (9th Cir. 1994) F.3d 1405)


• 3:52 – Recent Office of Administrative Hearings (OAH) decisions regarding goals


• 5:03 – OAH on clarity in goal writing


• 5:22 – South Sutter Charter School case (Student v. South Sutter Charter School (OAH 2024) Case Nos. 2023100030/2023100175)


• 8:47 – Meeting the “stranger test”


• 9:52 – Goals and relationship to instruction and services


• 10:24 – LAUSD case (Student v. Los Angeles Unified School District (OAH 2024) Case No. 2023100526)


• 11:38 – Separate goals in relation to specific areas of need


• 12:18 – S.W. v. Capistrano case standard (Capistrano Unified School District v. S.W. (9th Cir. 2021) 21 F.4th 1125; Student v. Capistrano Unified School District (OAH 2023) Case No. 2023050289)


• 13:40 – Including underlying conditions in goals


• 15:44 – Baselines and Ukiah case (Student v. Ukiah Unified School District (OAH 2024) Case Nos. 2024010195/2023100750)


• 19:11 – Big picture takeaways

For more information on the topics discussed in this podcast, please visit our website at: www.lozanosmith.com/podcast.