however, is not directed to discerning whether there are disputed issues of fact, but rather, whether the administrative record, together with any additional evidence, establishes that there has been compliance with IDEA’S processes and that the child’s educational needs have been appropriately addressed.”). B. Obligations of Schools to Remedy Bullying 1. Due Process The central question raised by this case is what actions, if any, a school is required to take to stop bullying of disabled students. Generally, the Due Process Clause of the Constitution does not require that the state “protect the life, liberty, and property of its citizens against invasion by private actors.” DeShaney v. Winnebago County Dep’t of Soc. Services, 489 U.S. 189, 195, 109 S.Ct. 998 2, 73 L.Ed.2d 28 (1982) (<HOLDING>). See also, Ying Jing Gan v. City of New York,
holding that trial court abused its discretion in ordering chiropractor to disclose the identity of all patients that had any type of connection to the plaintiffs attorneys and to produce all billing records for services rendered to attorneys or patients holding that evidence of impaired mental functioning is inherently mitigating and that a defendant is not required to demonstrate a nexus between his mental capacity and the crime committed holding that the substantive component of the fourteenth amendments due process clause requires the state to provide involuntarilycommitted mental patients with such services as are necessary to ensure their reasonable safety from themselves and others holding that the state must provide involuntarily committed mental patients with services that insure their reasonable safety holding that psychiatrist has duty to third parties to exercise due care in treatment and release of committed patients