Marilyn Beckford, et al. v. Melissa Aviles-Ramos, et al.

CourtDistrict Court, S.D. New York
DecidedSeptember 30, 2025
Docket1:24-cv-09930
StatusUnknown

This text of Marilyn Beckford, et al. v. Melissa Aviles-Ramos, et al. (Marilyn Beckford, et al. v. Melissa Aviles-Ramos, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marilyn Beckford, et al. v. Melissa Aviles-Ramos, et al., (S.D.N.Y. 2025).

Opinion

USL SUNT DOCUMENT UNITED STATES DISTRICT COURT ee SOUTHERN DISTRICT OF NEW YORK NO ice DATE FILED:__ □□□□□□□□□ MARILYN BECKFORD, et al., ———————— Plaintiffs, -against- 24-CV-09930 (MMG) MELISSA AVILES-RAMOS, et al., OPINION ORDER Defendants.

MARGARET M. GARNETT, United States District Judge: Plaintiffs Marilyn Beckford and Brianna Davis are parents of children with disabilities who have obtained administrative orders pursuant to the Individuals with Disabilities Education Act (“IDEA”) requiring the New York City Department of Education (“DOE”) to fund their children’s placement at a specialized private school, the International Institute for the Brain (“1Brain”). They bring this action individually and on behalf of their children—M_B. and O.D., respectively—against DOE and Melissa Aviles-Ramos, in her official capacity as Chancellor of the DOE (together, “Defendants”), asserting substantive claims under the IDEA and 42 U.S.C. § 1983, as well as a claim for attorneys’ fees under the IDEA. Additionally, Plaintiffs have moved for a preliminary injunction compelling compliance with the underlying administrative order applicable to Davis. Defendants oppose the motion for a preliminary injunction and have moved to dismiss the Complaint. For the reasons that follow, the motion for a preliminary injunction is DENIED. Defendants’ motion to dismiss is GRANTED as to the substantive IDEA claim asserted by Plaintiff Beckford and as to the Section 1983 claims by Beckford and Davis. Defendants’ motion to dismiss is DENIED as to the claim for attorneys’ fees. Further, Davis is hereby ORDERED TO SHOW CAUSE why her IDEA claim should not be dismissed as moot.

BACKGROUND L STATUTORY FRAMEWORK “The IDEA authorizes the disbursement of federal funds to [s]tates that develop appropriate plans to, among other things, provide a free and appropriate public education (‘FAPE’) to children with disabilities.” Ventura de Paulino v. N.Y.C. Dep’t of Educ., 959 F.3d 519, 525 (2d Cir. 2020).! “To provide a FAPE to each student with a disability, a school district must develop an [Individualized Education Program (“IEP”)] that is ‘reasonably calculated to enable the child to receive educational benefits.’” Jd. (quoting 7.M. ex rel. A.M. v. Cornwall Cent. Sch. Dist., 752 F.3d 145, 151 (2d Cir. 2014)). Parents who wish to challenge the adequacy of their child’s IEP or its implementation can avail themselves of New York’s two-tier system of administrative review: first, by filing an administrative due process complaint (“DPC”) and requesting a hearing before an Impartial Hearing Officer (“THO”); and second, by appealing that officer’s decision to a state review officer (“SRO”). 20 U.S.C. §§ 1415(fH(g); N.Y. Educ. Law §§ 4404(1)}1(2). The IDEA permits dissatisfied parents to pursue judicial review of an SRO’s decision in a federal district court. Ventura, 959 F.3d at 526; see also 20 U.S.C. § 1415(4)(2)(A); N.Y. Educ. Law § 4404(3). The district court receives the records of the state administrative proceedings and hears additional evidence if requested. 20 U.S.C. §§ 1415(@)(2)(C)@)-1i). II. RELEVANT FACTS Between June and July 2024, Plaintiffs filed DPCs alleging that the DOE did not provide their respective children with a FAPE. Compl. ff 36, 53, Dkt. No 1. Beckford alleged that M.B.

1 Unless otherwise indicated, case quotations omit all internal citations, quotation marks, footnotes and omissions, and adopt alterations.

was not provided a FAPE during the 2024—2025 school year. Jd. { 36. Her DPC was assigned to THO Robin Levin under IHO Case No. 277132. Id. § 37. Davis alleged that O.D. was not provided a FAPE during the 2023—2024 and 2024—2025 school years. Jd. 53,56. Her cases were assigned to IHO Jessica Mendoza and consolidated under IHO Case No. 275799. Id. 53-60. On October 14, 2024, THO Levin issued her Findings of Fact and Decision (““FOFD”) with respect to IHO Case No. 277132. Jd. 39. THO Levin found that M.B. was not provided a FAPE for the 2024—2025 school year and that iBrain was an appropriate unilateral placement for M.B. during that school year. Jd. § 40. She ordered DOE to fully fund M-B.’s tuition, costs, expenses, related services, and transportation services at iBrain for the 2024—2025 school year. Id. § 41. Specifically, the FOFD stated that “[DOE] shall directly pay [iBrain] pursuant to the terms of the tuition agreement within 35 days of the date of this Order” and that “[DOE] shall directly pay fund the cost of specialized transportation services for the Student . . . pursuant to the terms of the transportation agreement with the Transportation Provider within 35 days of the date of this Order.” Jd. § 41. DOE did not appeal THO Levin’s order. Id. § 47. On August 28, 2024, IHO Mendoza issued an FOFD in IHO Case No. 275799. THO Mendoza determined that DOE did not deny O.D. a FAPE for the 2023—2024 and 2024-2025 school years. Jd. § 61-62. Davis appealed the decision. Jd. § 63. On December 4, 2024, SRO Justyn Bates issued SRO Decision 24-432, reversing IHO Mendoza’s FOFD and finding that DOE denied O.D. a FAPE for the 2023—2024 and 2024—2025 school years and that iBrain was an appropriate unilateral placement for O.D. during those school years. Jd. 65-66. SRO Bates ordered that DOE “shall directly fund the cost of [D.O.’s] attendance for the 12-month 2023-24 and 12-month 2024-25 school years in accordance with the enrollment contracts” and

that DOE “shall directly fund the cost of [D.O.’s] transportation for the 12-month 2023—24 and 12-month 2024—25 school years in accordance with the transportation contracts.” Jd. § 67. Plaintiffs allege that the DOE has failed to comply with the FOFD in IHO Case No. 277132 and SRO Decision 24-432 in IHO Case No. 275799 (together, the “Administrative Orders”). Jd. 51, 70,100, 106. With respect to the order for M-B.’s tuition and related services, the Complaint alleges that DOE has not paid “late fees” that Beckford has incurred because of DOE’s delayed payment. Jd. 51 n.3. With respect to the order for O.D.’s tuition and related services, the Complaint alleges that DOE has not funded the total costs as ordered and that DOE’s delay puts Davis at risk of incurring “late fees.” Jd. 71. Il. PROCEDURAL HISTORY Plaintiffs initiated this case on December 24, 2024, asserting three causes of action. Dkt. No. 1. First, the Complaint brings a claim for violation of Plaintiffs’ rights under the IDEA, its implementing regulations, and New York State Education Law. Jd. ¥{98—99. Second, the Complaint brings a claim under 42 U.S.C. § 1983, alleging that DOE’s failure to comply with the Administrative Orders was pursuant to a systemic DOE policy or practice. Jd. 101-114. Third, the Complaint brings a claim for attorneys’ fees, asserting that each Plaintiff was the “prevailing party” in their respective administrative proceedings below and thus entitled to an award of attorneys’ fees under the IDEA. /d. 9 115-128. Among other relief, Plaintiffs seek a preliminary injunction or other order requiring DOE to comply with the Administrative Orders, and a judgment awarding Plaintiffs “late fees,” nominal damages, attorneys’ fees and costs, “fees on fees” and costs incurred in prosecuting this federal action. Jd. at 18—19.

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Marilyn Beckford, et al. v. Melissa Aviles-Ramos, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/marilyn-beckford-et-al-v-melissa-aviles-ramos-et-al-nysd-2025.