When Transition Assessment Is Non-Negotiable: C.M.E. v. Shoreline School District (2023)

Multidisciplinary teams are responsible for developing legally compliant individualized education programs for transition-age students with disabilities. A critical component of this process is the use of age-appropriate transition assessments to inform postsecondary goals and transition services. However, the assessment process can become challenging when team members differ in their perspectives on the types or extent of evaluations needed to support transition planning. For example, a dispute may arise when a parent seeks to limit the scope of special education evaluations. In C.M.E. on behalf of W.P.B. v. Shoreline School District (2023), a decision from the U.S. Court of Appeals for the Ninth Circuit addressed whether parents may refuse components of an evaluation required under the Individuals with Disabilities Education Improvement Act of 2004. The court concluded that parents may refuse special education services but cannot dictate the assessments within an evaluation. Implications and strategies to support collaborative transition planning with families are discussed.