"The IDEA is a complex Federal grant program intended to ‘ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs.’ " Commonwealth v. Nathaniel N., 54 Mass. App. Ct. 200, 202, 764 N.E.2d 883 (2002), quoting 20 U.S.C. § 1400(d)(1)(A) (Supp. 1999).
In Commonwealth v. Nathaniel M., the Massachusetts Appeals Court found that the school's reporting to the police of a juvenile for possession of marijuana in school did not trigger a change in placement under the IDEA. See 764 N.E.2d 883, 886-87 (Mass.App.Ct. 2002). Thus, the scant caselaw available weighs against Plaintiffs' arguments.