R.T. by and through his guardian ad litem, David Tsukiyama v. San Diego Unified School District

Summary

The United States District Court for the Southern District of California grants San Diego Unified School District’s motion to supplement the administrative record in an Individuals with Disabilities Education Act action. The court finds that email correspondence, attendance records, and an enrollment agreement are relevant, non-cumulative, authenticated, and admissible. The order does not address the merits of the underlying litigation.

Holdings

1. A federal court reviewing an IDEA administrative decision may admit supplemental evidence when it is relevant, non-cumulative, and otherwise admissible, provided that supplementation does not change the proceeding from administrative review into a trial de novo.
2. The proposed records were self-authenticating because the District submitted a custodian declaration establishing the requirements for certified domestic records of regularly conducted activity.
3. The email correspondence, attendance records, and Enrollment Agreement were relevant, non-cumulative, and otherwise admissible for purposes of supplementing the administrative record.

Questions Presented

1. Whether the District could supplement the IDEA administrative record with the subpoenaed email correspondence, attendance records, and Enrollment Agreement.
2. Whether the proposed supplemental evidence was authenticated and admissible under the Federal Rules of Evidence.
3. Whether the proposed evidence was relevant and non-cumulative.

Disposition

other