I have to say that this story really appalls me, especially as someone who works on the school side of things. If it truly is being used punitively, or to manipulate the family, it is completely unethical.
FYI, if you really want to scare a school system, invoke the Office of Civil Rights--as in, my child, identified with a disability, is being discriminated against, in the form of punitive actions against the family in response to advocacy for the child, or denial of services without a reasonable explanation. I would save actually filing for a last resort, though, as it will pretty much kill any remaining relationship you have with the school.
If OCR decides there are grounds for an investigation, they can turn over just about any rock they want to, including all kinds of things not that closely related to the original complaint.
