What is the definition of school placement under the Individuals with Disabilities Education Act, and when does a change in placement occur?

QUESTION PRESENTED FOR REVIEW I. As school placement is an essential element of the Individuals with Disabilities Act, 20 USC §§ 1400 et. seq., and to the provision of a Free and Appropriate Education, the statute fails to define school placement, the Circuits have aé_ variety of fundamentally different formulas for determining placement, and school districts are more commonly changing a student’s location of services without first making a team decision to change the _ students placement where those districts have distinguished location of services from i placement, Petitioner requests this Court define what a school placement is and, accordingly, when a change in placement occurs. II. Whether, in the event that there was a change in placement in this matter, Respondent denied Z.B. a FAPE by committing the procedural violation of preventing Petitioner from meaningfully participating in Z.B.’s IEP meeting by predetermining his new placement and accordingly unilaterally reducing the hours of individualized instruction in the IEP to accommodate the new placement. ii PARTIES IN COURT BELOW Other than Petitioner and Respondent, the other parties are as follows: 1. Z.B. is a child and a disabled student in the District of Columbia. 2. Sylvia Sanchez is the mother/parent of Z.B. 3. The District of Columbia/ District of Columbia Public School System, is the Local Educational Agency charged with providing Z.B. a Free and Appropriate Public Education. iii