Individualized education programs are considered the cornerstone of the Individuals With Disabilities Education Act and serve as the means to determine whether qualified students with disabilities receive a Free Appropriate Public Education. This article aims to examine a recent circuit court ruling regarding the applicability of retrospective testimony to determine the appropriateness of an individualized education program and to discuss implications for practice. The authors first review case law and provide a summary of the court's rationale. They subsequently discuss implications for practice.