PHILLIP C. v. JEFFERSON COUNTY BOARD OF EDUCATION (11th Cir., decided 11/21/12): The Court rejected the district’s argument that the federal regulation authorizing a parent's right to an independent evaluation at district expense exceeded the scope of the IDEA. The District argued that the IDEA did not specify that state and local agencies must finance a parent's IEE and thus, although the parent had a right to an IEE, the district did not have to pay for it.