In M.B. v. Hamilton Southeastern Schools, the Seventh Circuit rejected the parents’ procedural and substantive claims because the procedural errors did not prevent the parents from participating in the IEP process or impact the student’s IEP, and the student was making progress toward his IEP goals.

M.B. suffered a traumatic brain injury at the age of four, and his parents sought special education services from Hamilton Southeastern Schools. The parents contacted the school in early December 2007, but did not consent to an evaluation until late January 2008, after they received the report of the neuropsychologist they hired to evaluate M.B. The school convened a case conference meeting for M.B. at the end of April, where the committee found M.B. eligible for special education services and developed an IEP. The parents agreed with the IEP, which called for a half-day early childhood program and related services.

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