... DS in an astoundingly lack of good judgement (not unusual in him - he can be oblivious) didn't clue in that it was a geography AND spelling test, and had a "cheat sheet" of locations in his lap.
The teacher's comment re: LD does seem quite rotten to me.
Regarding the self-described "cheat sheet" though, how would it have been any less of a cheat if the test were only about geography and not about spelling?
This is precisely why I jumped all over our son for a seemingly innocuous cheat last year. "Lie=Cheat=Steal" was the topic of our conversation that whole afternoon. And I also explained to him that were he ever labeled a "cheater," it would be pretty darned tough to undo.
It sounds like this cheating incident may have really upset his teacher, and should probably be resolved before pressing for any accommodations.