CALLAHAN, Circuit Judge, concurring: I concur in the opinion, but write separately because I share the concern expressed by Judge Bea in his separate concurrence and dissent that our clarification of IDEA’S exhaustion requirement, 20 U.S.C. § 1415 (Z), may be used to circumvent the requirement. Even under the “relief-centered” approach we adopt, it is not always possible…
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