M.C. et al v. Williamsport Area School District

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
M.C., by and through his Parents,
K.J-C and J.C., and K.J-C and J.C.,
individually,
Plaintiffs,
v.
WILLIAMSPORT AREA SCHOOL
DISTRICT,
Defendant.
No. 4:25-CV-01831
(Chief Judge Brann)
MEMORANDUM OPINION
MARCH 18, 2026
This action was filed under the Individuals with Disabilities Education Act
(hereinafter “IDEA”) on September 30, 2025.1 Plaintiffs alleged that Williamsport
Area 	School 	District 	(hereinafter 	“District”) violated 	M.C.’s 	right 	to 	a 	free
appropriate public education.2 Plaintiffs sought a reversal of a hearing officer’s
previous decision and order in this case and tuition reimbursement for M.C.’s
placement at a private school.3 After the initial complaint was filed, the District filed
a counterclaim seeking the reversal of a different portion the hearing officer’s
decision that granted M.C. compensatory education.4
1 	Doc. 1.
2 	See id. at 24-25.
3 	See id.
4 	See Doc. 5.
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On 	December 	12, 	2025, 	Plaintiffs 	filed 	a 	motion 	to 	supplement 	the
administrative record. 5 The motion has been fully briefed and is now ripe for
disposition; for the reasons that follow, it is granted in part and denied in part.
I. 	LAW
Under 	IDEA, 	“a 	party 	aggrieved 	by 	the 	findings 	and 	decision 	of 	an
administrative panel has the right to bring a civil action in federal court for judicial
review.” 6 When such a suit is filed, the court shall “(1) receive the records of the
administrative proceedings; (2) hear additional evidence at the request of the party;
and (3) base its decision on a preponderance of the evidence, as well as grant such
relief as it determines appropriate.”7 As referenced by that second requirement, a
district court hearing this type of action has explicit authority under IDEA to hear
evidence that is not directly in the administrative record. 8
Ultimately, 	“whether 	a 	district 	court 	hears 	additional 	evidence 	is
discretionary.” 9 In deciding whether to allow additional evidence to come into the
record, 	“a 	court 	may 	neither 	summarily 	exclude 	proffered 	evidence 	before
evaluating its content; nor may a court grant a party carte blanche to introduce
5 	See Doc. 9.
6 	A.H. by & through K.P. v. Colonial Sch. Dist., No. CV 16-726-RGA-MPT, 2017 WL 1395508,
at *2 (D. Del. Apr. 17, 2017) (citing 20 U.S.C. § 1415(i)(2)(B)), aff’d, 779 F. App’x 90 (3d
Cir. 2019).
7 	Id. (citing 20 U.S.C. § 1415(i)(2)(C)).
8 	See Susan N. v. Wilson Sch. Dist., 70 F.3d 751, 758 (3d Cir. 1995).
9 	M.S. by & through Emily S. v. Downingtown Area Sch. Dist., No. 20-CV-5085-JMY, 2022 WL
16531962, at *16 (E.D. Pa. Oct. 28, 2022) (citing Susan N., 70 F.3d at 759).
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evidence that was not offered at the administrative hearing, and thus render the
administrative proceedings a mere formality.” 10
Instead, 	a 	court 	“must 	exercise 	particularized 	discretion” 	to 	determine
whether 	the 	proffered 	evidence 	is 	“relevant, 	non-cumulative, 	and 	useful.”11
Additionally, “a court must determine whether the party introducing the additional
evidence has presented a sufficient justification for not proffering the evidence at the
administrative hearing.”12 Finally, it is important to note that allowances of
additional evidence “does not authorize witnesses at trial to repeat or embellish their
prior administrative hearing testimony.”13
When conducting this described analysis, the Court must keep in mind that
the central goal of IDEA is “to ensure that each child with disabilities has access to
a program that is tailored to his or her changing needs and designed to achieve
educational progress.” 14 The purpose of exercising “particularized discretion” in this
decision is to ensure that the Court considers all evidence that is “relevant, non-
cumulative and useful in determining whether Congress’ goal has been reached for
the child involved.” 15 Therefore, the “standard in determining whether to admit the
10 	Id. (emphasis in original) (citing Antoine M. v. Chester Upland Sch. Dist., 420 F. Supp. 2d 396,
402 (E.D. Pa. 2006)).
11 	Susan N., 70 F.3d at 760.
12 	Breanne C. v. S. York Cnty. Sch. Dist., No. 1:08-1526, 2010 WL 773945, at *1 (M.D. Pa. Feb.
26, 2010) (citing Susan N., 70 F.3d at 760).
13 	A.H., 2017 WL 1395508, at *2.
14 	Susan N., 70 F.3d at 760.
15 	Id.
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proffered additional evidence” is asking the question of: “would the evidence assist
the court in ascertaining whether Congress’ goal has been and is being reached for
the child involved.” 16
II. 	ANALYSIS
While the briefing on this motion includes a great deal of discussion about the
veracity of the exhibits proffered by plaintiff, only two of the exhibits—H and I—
can even be properly described as “additional evidence.” This is because all of other
exhibits are either a part of the administrative record, or the relevant portion of the
exhibits are a part of that record.17 All of these exhibits are 	included within “the
records of the administrative proceeding.” 18 That is to say, that these exhibits — or
the links to videos and quotations from articles within them — are properly before
16 	Id.
17 	These exhibits appear in the administrative record as follows. Exhibit A is a copy of the hearing
officer’s pre-hearing order, which appears in the administrative record. See Doc. 8-11. Exhibit
B is a copy of the parent’s amended statement of issues in the administrative proceeding, while
Exhibit G shows emails between them and the hearing officer. See Doc. 10, Exs. B & G. Both
of these exhibits discuss a YouTube video that explains the utility of the private school’s
reconstructive language program. See Doc. 10, Exs. B & G. But a URL link to that video is
already in the administrative record, within the Parent’s exhibits. See Doc. 8-10 (labeled within
parent’s exhibits as “P-33”). Both M.C.’s mother’s deposition and Dr. Kachmer’s deposition,
Exhibits C and D of this motion, also appear within the Parent’s exhibits within the
administrative record. See Doc. 8-10 (labeled within parent’s exhibits as “P-36” and “P-37”).
Exhibit E is a copy of the Parents’ written closing argument which appears in the administrative
record explicitly. See Doc. 8-4. It also appears that URL links to the videos that Plaintiffs are
referencing withing that closing arguments are also in the administrative record. See Doc. 8-
10 (labeled within parent’s exhibits as “P-18”). Exhibit G provides a copy of the hearing
officer’s final decision and order, which are part of the administrative record. See Doc. 8-3.
Finally, the relevant portion of the article that Plaintiffs submitted as Exhibit J is also contained
within the administrative record. See Doc. 8-5, at 14-15.
18 	20 U.S.C. § 1415(i)(2)(C)(i).
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the Court and will be considered by the Court. Because these Exhibits proffer
material already in the record, they are cumulative and will not be admitted as
additional evidence in this case.
However, Exhibits H and I are reports from the new school that M.C. is
attending, which detail his progress at that school.19 These reports were either
compiled immediately before or at some time after the hearing officer’s decision was
rendered. As a result, they were understandably not a part of the administrative
proceedings and were not considered by the hearing officer.
The United States Court of Appeals for the Third Circuit has left “open the
possibility that an administrative hearing record may be supplemented with evidence
concerning relevant events occurring subsequent to the administrative hearing.” 20
But it has made clear that such evidence “may be considered only with respect to
the reasonableness of the district's decision at the time it was made.” 21 This means
that this evidence cannot be used as a form of “Monday Morning Quarterbacking in
evaluating the appropriateness of a child’s placement.” 22
At this juncture it is not clear to the Court whether the reports will be relevant
to the ultimate disposition of this case. However, the Court also cannot definitively
19 	See Doc. 10, Exs. H & I.
20 	J.C. v. Upper Darby Sch. Dist., No. CV 20-5030, 2022 WL 4473598, at *1 (E.D. Pa. Sept. 26,
2022) (quoting Susan N. v. Wilson Sch. Dist., 70 F.3d 751, 758 (3d Cir. 1995)) (internal
quotation marks omitted).
21 	Susan N., 70 F.3d at 762 (emphasis in original).
22 	Id. (internal quotation marks omitted).
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state they will be wholly irrelevant to a resolution of this matter. Defendants are
correct that these reports are not clearly relevant to an evaluation of the District’s
decisions about M.C.S’s educational program at the time the decisions were made. 23
But there remains a possibility that they could be helpful. Additionally, the hearing
officer included a section in his decision about the appropriateness of the private
school where M.C. is placed. 24 These reports seem directly relevant to a rebuttal of
“the adverse inference” derived in that section about the appropriateness of the
placement. 25 Other courts in this circuit have found that when the district “did not
have to determine at the time it offered the IEP whether [the private school] was an
appropriate placement,” additional evidence may still be relevant to and admitted in
an IDEA analysis.26
While this evidence can only be used to analyze the “reasonableness of the
district’s decision at the time it was made,”27 there remains a chance that these
reports will assist this Court in determining “whether Congress’ goal in enacting the
23 	See Doc. 11, at 11. For a detailed discussion of why these progress reports may not relevant
for this purpose see Lebron v. N. Penn Sch. Dist., 769 F. Supp. 2d 788, 796 (E.D. Pa. 2011).
24 	Doc. 8-3, at 39-40.
25 	Id. at 40. Ultimately, this Court believes that these reports may prove “useful in determining
whether the goals of the IDEA have been reached for the child involved.” R.G. ex rel. Maria
G. v. Downingtown Area Sch. Dist., 528 F. App’x 153, 156 (3d Cir. 2013). It is for this reason
that these two exhibits will be admitted at this time. But it should be noted that they “may not
play a significant role in the final resolution of the case.” See J.C. v. Upper Darby Sch. Dist.,
No. CV 20-5030, 2022 WL 4473598, at *3 (E.D. Pa. Sept. 26, 2022).
26 	See A.Y. v. Cumberland Valley Sch. Dist., 569 F. Supp. 2d 496, 507-08 (M.D. Pa. 2008)
27 	Susan N. v. Wilson Sch. Dist., 70 F.3d 751, 762 (3d Cir. 1995). The Court acknowledges that
this evidence can only be used for this purpose. In the event that these reports are utilized to
resolve this case, their consideration will be in alignment with this purpose. But at this stage,
the Court believes that it would be premature to bar the admission of these reports.
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IDEA has been reached for [M.C.]. ”28 Therefore, these reports will be admitted as
additional evidence.
To summarize, of the exhibits submitted as additional evidence by Plaintiffs,
only Exhibits H and I will be admitted.
III. 	CONCLUSION
For 	the 	foregoing 	reasons, 	Plaintiffs’ 	Motion 	to 	Supplement 	the
Administrative Record is granted in part and denied in part.
An appropriate Order follows.
BY THE COURT:
s/ Matthew W. Brann
Matthew W. Brann
Chief United States District Judge
28 	H.M., ex rel. her parents v. Haddon Heights Bd. of Educ., No. CIV.094293NLHAMD, 2010
WL 2571976, at *5 (D.N.J. June 22, 2010).
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