Moody Ex Rel. J.M. v. NYC Department of Education, 513 F. App'x 95

Moody appeals pro se on behalf of herself and her son J.M. from a district court grant of summary judgment to NYC Department of Education and related defendants.
District Court held there was no genuine dispute of material fact and Moody was not entitled to the requested accommodations.
The issue centers on whether heating J.M.’s food was necessary to provide meaningful access under the Rehabilitation Act and ADA.
Court noted that accommodations already provided—lunch options and blood glucose monitoring—helped achieve meaningful access to public school lunches.
Moody challenges the district’s interpretation of what constitutes an adequate accommodation for a diabetic student.
The panel reviews de novo the grant of summary judgment and the denial of reconsideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether heating J.M.’s food was required.	Moody argues heating aids disability access.	District argues not required; optimal not mandated.	No; heating not required to provide meaningful access.
Whether the provided accommodations were sufficient under §504/ADA.	Accommodations were inadequate for J.M.’s needs.	Accommodations (menu options, glucose monitoring) were sufficient for meaningful access.	Yes; existing accommodations afforded meaningful access; no further need.

Alexander v. Choate, 469 U.S. 287 (U.S. 1985) (meaningful access not equal to optimal accommodations)
Henrietta D. v. Bloomberg, 331 F.3d 261 (2d Cir. 2003) (treatment of Section 504 and ADA claims identically)
J.D. ex rel. J.D. v. Pawlet Sch. Dist., 224 F.3d 60 (2d Cir. 2000) (no requirement for optimal accommodations)
Gould v. Winstar Commc’ns, Inc., 692 F.3d 148 (2d Cir. 2012) (standard for summary judgment de novo review; draw inferences for non-movant)
Nationwide Life Ins. Co. v. Bankers Leasing Ass’n, 182 F.3d 157 (2d Cir. 1999) (ambiguities resolved in favor of non-movant in summary judgment)