In L.B. v. San Diego Unified School District (9th Cir. 2026) 168 F.4th 1150, the Ninth Circuit Court of Appeals held that both the District Court and the Office of Administrative Hearings (OAH) erred in holding that a school district was not required to offer a free appropriate public education (FAPE) to a parentally-placed private school (PPPS) child if the parents requested an “IE