Judge Rotenberg Educational Center v. Blass, 679 F. App'x 71

JRC (Judge Rotenberg Educational Center) cared for RP, a disabled young woman in foster care, and sought restitution from Suffolk County DSS (SCDSS) for housing, educational, and legal services it provided on SCDSS’s behalf.
District court granted summary judgment to JRC on restitution; SCDSS appealed but did not contest the award amount.
Key timeline: RP turned 21 in January 2009; SCDSS lacked a permanent placement for her and instructed JRC to take RP to a homeless shelter—contrary to New York regulations forbidding discharge to shelters without a stable residence expected to last 12 months.
RP remained without a permanent placement for 11 months after SCDSS proposed shelter placement; JRC continued to provide care during that period and billed SCDSS.
SCDSS argued (1) it had no duty after RP turned 21 and (2) JRC was an officious intermeddler (gratuitous provider) barred from restitution. The district court rejected both arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether SCDSS breached a duty to plan for RP’s discharge from foster care	JRC: SCDSS failed to secure a permanency resource before RP turned 21, violating state regulations and its contract	SCDSS: Duties ended when RP turned 21, so no obligation to arrange placement	Court: SCDSS breached state-law duty to plan transitional care; failure supports restitution
Whether JRC was an officious intermeddler and thus barred from restitution	JRC: It was contracted to care for RP, continued custody with SCDSS knowledge, and expected payment	SCDSS: JRC gratuitously maintained RP and thus cannot recover	Court: JRC was not officious; SCDSS knew of bills, agreed to bear responsibility, and created a reasonable expectation of payment, so restitution permitted

Walsh v. N.Y.C. Housing Auth., 828 F.3d 70 (2d Cir. 2016) (standard of review for summary judgment)
Central Laborers’ Pension Fund v. Blankfein, 111 A.D.3d 40 (N.Y. App. Div. 2013) (officious intermeddler doctrine explained)