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:: Example: In other cases, we did not articulate any standard at all, granting reimbursement automatically after determining that the school district failed to provide a free appropriate public education and that the student was placed in an appropriate private school.

See, e. g., Capistrano, 59 F. 3d at 896-97 ; Union Sch.

Dist.

v. Smith, 15 F. 3d 1519, 1527 ( 9th Cir. 1994 ).