Hearing Officer Profile

Sarah Smith Freeman

VDOE Case No. 27-026

Current proceeding. This profile addresses the September 2026 prehearing and insufficiency record presently available. Several issues remain contested and were the subject of motions to vacate and a disqualification request.

Parent's constitutional and IDEA theory

In VDOE Case No. 27-026, Hearing Officer Sarah Smith Freeman entered a September 28, 2026 insufficiency ruling and dismissed the matter without prejudice pending an amended request. Her ruling stated that the Parent had not specified a reimbursement amount or identified compensatory educational services with sufficient detail and warned of possible sanctions for future noncompliance or conduct. The Parent contends that the ruling imposed requirements beyond IDEA's notice standard, ignored compensatory-service categories already stated in the complaint, addressed a reimbursement theory the complaint did not request, and was entered without a fair opportunity to answer APS's renewed dismissal motion.

Concrete procedural record

Insufficiency theory. Freeman's ruling identified absence of a reimbursement amount and asserted lack of sufficient compensatory-service detail as grounds requiring amendment.

Complaint language identified by Parent. The Parent's opposition points to the complaint's express request for compensatory education including independent tutoring, executive-function coaching, counseling or related services, make-up opportunities, and independent educational evaluations, with amount and provider terms to be determined on the evidence.

Prior contrary sufficiency ruling. The Parent's opposition cites Hartsoe's July 7, 2026 written ruling in the prior case finding a materially similar request sufficient and stating it gave APS ample information to prepare.

Sanctions and recusal. Freeman's written ruling dismissed without prejudice and warned that future conduct could lead to communication restrictions or dismissal with prejudice. Her ruling also acknowledged that she had seen the Parent's recusal challenge and denied its allegations.

Alleged procedural manipulation

The Parent alleges that APS reframed a merits dispute as a pleading or compliance problem and that Freeman accepted that framing at the prehearing stage, allowing the proceeding to halt before evidence was taken. Freeman's stated rationale was that additional information was needed to define the dispute and permit the parties to proceed.

Project sources

September 28, 2026 Insufficiency Response and Dismissal, VDOE 27-026; Parent's Revised and Supplemental Opposition and Motion to Vacate; disqualification materials; September 4, 2026 complaint relief section.