Before expelling a student with a disability, schools must first conduct a manifestation determination to determine whether the student’s misconduct was caused by or had a direct and substantial relationship to the student’s disability. In Poway Unified School District, 55 IDELR 152 (SEA CA 2010), an administrative law judge (ALJ) examined whether the decision of an 8th grade boy to build and detonate a dry-ice bomb in the school’s bathroom was an impulsive act, as claimed by the parent and outside doctors. After consideration of the facts, the ALJ concluded that while the misconduct reflected poor judgment, it was not the result of the student’s impulsivity and therefore not a direct result of the student’s ADHD. In supporting the conclusion reached by the school team, the ALJ noted that the student had talked about and researched how to obtain dry ice a couple of weeks before the incident; had carefully constructed the bomb; had selected a location to hide and explode the bomb and waited for it to explode after placing it in a bathroom stall. These actions and events took place over a “significant period of time” and supported the conclusion that the student had “mulled over the steps required to construct and explode his dry ice bomb,” thus undermining any claim that the student’s actions were impulsive and directly related to his ADHD.