Procedural violations of the IDEA alone are usually not a basis for a court to find a student has been denied a free appropriate public education (FAPE). A recent decision by the United States Court of Appeal for the 2nd Circuit, however, found multiple procedural violations, did deprive a student of educational benefits he was entitled to under the law. K.T., a now twenty-year old autistic student, began attending a public special education school in the Bronx, New York in 2009. His mother, L.O., filed for due process in December 2011 after K.T. began to refuse to attend school. L.O. claimed the three IEPs developed for her son were inappropriat…