IN SEPTEMBER 1997, the Ridgewood, New Jersey, school district placed J.N., then age 11, in the Windsor School, per the IEP (individualized education program) team's identification of his special needs for structure, safety, and security. As a state-approved private special education school, Windsor signed an agreement with Ridgewood for the academic year. That first year went well. However, when J.N. returned to Windsor the following year, things went awry. J.N. did not like his new teacher. His parents made frequent telephone calls to school personnel, and J.N. was absent a lot. On December 16, feeling that these circumstances were making progress on J.N.'s IEP goals impossible, Windsor's co-owner and co-executive director, Daniel Greco, decided to terminate J.N.'s placement in the school. At the district's request, Greco agreed to continue J.N.'s enrollment until December 23, when the holiday break began, but insisted that the boy could not return when the second semester started on January 4. He confirmed this decision in a December 21 letter to the district's special education director, John Campion. At about the same time, the parents directed a letter to Campion asking what he planned to do in response to "Windsor's irrational and inhumane treatment" of their son. He forwarded their letter to Greco. On December 22, Campion faxed the parents a letter informing them that the IEP team chair had proposed an "excellent" placement at another special school. The letter was accompanied by authorizing forms, which Campion requested the parents to sign and return ASAP. The parents returned the forms and visited the proposed school. However, on January 4, the parents faxed Campion a series of demands. First, as a prerequisite for any termination plan, they demanded that he convene an IEP team with participants from both Ridgewood and Windsor School. Second, they demanded that Ridgewood provide one-to-one tutoring, with transportation, during the interim between the beginning of the new semester and J.N.'s transfer to the new school. Campion faxed back a letter recounting the recent events and informing them that an intake interview was expected that week and that the IEP case manager was going to make immediate arrangements with them to revise the IEP on an interim basis and to provide instructional services in the home during the short transition. He cc'd the letter, without the parents' authorization, to Greco. J.N. did not receive the home services. On January 25, after Campion had provided the parents with information about several other schools, J.N. began to attend one of them per a new, agreed-upon IEP. He made satisfactory progress at the new school, completing his placement there three years later, in December 2001. He then received one-to-one instruction, which took place at the Ridgewood Library, for the rest of that school year. After that, the IEP team, including his parents, determined that he could enter the high school. Meanwhile, on 1 February 1999, the parents filed for a due process hearing, claiming that the district and Windsor had terminated J.N.'s placement in violation of IDEA and related state regulations and that during the interim before the new placement the family had had to contract for adult supervision and a psychiatrist. Soon thereafter, they filed a complaint with the state education department. On June 3, the hearing officer issued a decision that found that Windsor had violated state regulations by not providing written notice at least 15 days prior to termination and that the district had violated state regulations by not quickly convening an IEP meeting, including representation from the private school. However, she concluded that the gap of 17 school days between placements did not warrant compensatory education under the Third Circuit's standards. She also rejected the requested reimbursements for the adult supervision and psychiatrist as having "nothing to do with the provision of [free appropriate public education]. …