All federal appeals courts that have addressed this issue have turned away lawsuits for money damages for what might be called “educational malpractice” when cases are brought only under the Individuals with Disabilities Education Act (IDEA), including California, which is controlled by the Ninth Circuit Court of Appeals. [MountainView-Los AltosUnionH.S. Dist. v. SharronB.H., 709 F.2d 28, 31 (9th Cir. 1981).]