Did DCPA deny students FAPE?

Did the DCPA leadership's failure to implement their own board-approved code of conduct such as policies addressing In-School Suspension and School Dentention lead to a denial of FAPE?

From the inbox:

Consequences listed in our board-approved code of conduct such as In-School Suspension and School Detention do not exist at our school.  Protocols for procedures in the code of conduct such as student removal from classroom do not exist.

And this...

Last Spring, a number of students who were challenges behaviorally were put by the administration on a half-day schedule, meaning some missed reading or math class for the remainder of the year.  This decision was often made without
consulting teachers. At least two students were not allowed to come back to school for the last month; teachers were told to send home weekly packets - no other accommodations were made.

Apparently, it's happened before...  http://www.doe.k12.de.us/infosuites/students_family/specialed/files/DEDP09-12RStudvsDECPrep.pdf