J.C. v. Katonah-Lewisboro School District
690 F. App'x 53
| 2d Cir. | 2017Background
- T.C., a child with multiple disabilities affecting attention, learning, and motor skills, attended the Katonah-Lewisboro School District through 3rd grade and the Prospect School (private) in 4th–6th grades; reimbursement sought only for 5th–6th grades.
- Parents privately obtained neuropsychological evaluations recommending an 8:1:1 special-education classroom (8 students : 1 teacher : 1 aide); the School District’s IEPs proposed a 12:1:2 classroom.
- Parents sought tuition reimbursement under the IDEA after placing T.C. at Prospect; an IHO granted reimbursement but the State Review Officer (SRO) reversed.
- The district court granted summary judgment to the parents; the School District appealed to the Second Circuit.
- The Second Circuit reviewed whether (1) the School District failed to provide a FAPE, (2) the private placement was appropriate, and (3) the equities favored reimbursement, and whether the SRO’s decision merited deference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the School District failed to provide a FAPE because IEP class size (12:1:2) was too large for T.C. | 12 students would overwhelm T.C.; experts recommended 8:1:1, so 12:1:2 denied FAPE. | 12:1:2 has equivalent adult-to-student ratio and could be sufficient with accommodations. | Held for plaintiff: 12:1:2 insufficient; SRO’s reasoning unpersuasive; IHO determination adopted. |
| Proper deference to SRO vs IHO when SRO’s analysis is unpersuasive | IHO’s findings (favorable to parents) should be credited if SRO’s reasoning lacks persuasiveness. | SRO’s reversal should be afforded deference. | Held: Reduced deference to SRO because his reasons did not convincingly address expert evidence; court deferred to IHO. |
| Whether Prospect School placement was appropriate and equities favor reimbursement | Prospect provided specialized programming tailored to T.C.; parents cooperated with district—equities favor reimbursement. | Not reached by SRO; implied challenge to appropriateness/equities. | Held for plaintiff: IHO’s findings that Prospect was appropriate and equities favor reimbursement are supported and adopted. |
Key Cases Cited
- R.E. v. N.Y.C. Dep't of Educ., 694 F.3d 167 (2d Cir. 2012) (standard for FAPE and deference to administrative findings)
- M.H. v. N.Y.C. Dep’t of Educ., 685 F.3d 217 (2d Cir. 2012) (persuasiveness of administrative reasoning dictates degree of deference)
- C.F. ex rel. R.F. v. N.Y.C. Dep't of Educ., 746 F.3d 68 (2d Cir. 2014) (requirements for reimbursement: district failure, private placement appropriateness, and equitable considerations)
- Endrew F. ex rel. Joseph F. v. Douglas Cty. Sch. Dist., 137 S. Ct. 988 (2017) (Supreme Court interpretation of IDEA’s FAPE standard; noted but not dispositive here)