Zayas v. Banks

CourtCourt of Appeals for the Second Circuit
DecidedApril 8, 2025
Docket24-1076
StatusUnpublished

This text of Zayas v. Banks (Zayas v. Banks) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Zayas v. Banks, (2d Cir. 2025).

Opinion

24-1076-cv Zayas v. Banks

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 8th day of April, two thousand twenty-five.

PRESENT: ROBERT D. SACK, JOSEPH F. BIANCO, SARAH A. L. MERRIAM, Circuit Judges. ________________________________________________

ROSA ZAYAS, as Parent and Natural Guardian of R.Z. and Individually, EDWIN ZAYAS, as Parent and Natural Guardian of R.Z. and Individually,

Plaintiffs-Appellants,

v. 24-1076-cv

DAVID C. BANKS, in his official capacity as Chancellor of New York City Department of Education, NEW YORK CITY DEPARTMENT OF EDUCATION,

Defendants-Appellees. ________________________________________________

FOR PLAINTIFFS-APPELLANTS: RORY J. BELLANTONI (Carissa Shipley, on the brief), Brain Injury Rights Group, Ltd., New York, New York. FOR DEFENDANTS-APPELLEES: CHLOÉ K. MOON (Devin Slack, on the brief), for Muriel Goode-Trufant, Acting Corporation Counsel of the City of New York, New York, New York.

Appeal from the judgment of the United States District Court for the Southern District of

New York (Katherine Polk Failla, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND

DECREED that the judgment of the district court, entered on January 19, 2024, is AFFIRMED.

Plaintiffs-Appellants Rosa and Edwin Zayas, individually and as parents and natural

guardians of their son R.Z., appeal from the judgment of the district court granting summary

judgment in favor of Defendants-Appellees David C. Banks, in his official capacity as Chancellor

of the New York City Department of Education, and the New York City Department of Education,

and denying summary judgment to Appellants on their claims pursuant to the Individuals with

Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq., and Article 89 of the New York

Education Law, N.Y. Educ. Law § 4401 et seq. Appellants assert that Appellees failed to offer

R.Z. a free appropriate public education (“FAPE”) and that Appellants are entitled to

reimbursement of the costs of placing R.Z. at a private school. We assume the parties’ familiarity

with the underlying facts, procedural history, and issues on appeal, to which we refer only as

necessary to explain our decision to affirm.

BACKGROUND

At the time state proceedings in this case commenced, R.Z. was a sixteen-year-old student.

He suffers from cerebral palsy, seizure disorder, hydrocephalus, dystonia, and global

developmental delay, and is legally blind, non-ambulatory, and non-verbal. In March 2021, a

Committee of Special Education (“CSE”) was convened to formulate an Individualized Education

2 Program (“IEP”) for R.Z. for the 2021–2022 school year. Appellants were present at and

participated in this meeting. The CSE determined that R.Z. would receive services based on an

eligibility classification of traumatic brain injury and recommended an IEP that included, inter alia,

placement in specialized classes with low student-to-teacher ratios at a District 75 (“D75”) school; 1

individual occupational, physical, and speech-language therapy sessions; individual assistive

technology services; and specialized transportation. Appellees later determined that R.Z. would

be placed at the Horan School, a D75 school. Although they substantially agreed with the CSE’s

IEP recommendations, Appellants informed Appellees in June 2021 that they disagreed with

placing R.Z. at the Horan School. As a result of this disagreement, Appellants notified Appellees

that they intended to unilaterally enroll R.Z. at the International Institute for the Brain (“iBRAIN”),

a private school, for the 2021–2022 school year, and that they would seek reimbursement from

Appellees for the costs of attending that school. In July 2021, Appellants unilaterally reenrolled

R.Z. at iBRAIN for the 2021–2022 school year. 2

Later that year, in August 2021, the CSE reconvened to further assess R.Z.’s IEP as it related

to the IEP’s recommendations regarding assistive technology services. Although Appellees

contend that they emailed and called Appellants to inform them of when the meeting would occur,

Appellants assert that they received no such notice and therefore did not attend the meeting. As a

result of the August 2021 meeting, the CSE recommended that R.Z. receive largely the same

1 D75 schools are “highly specialized schools within the [New York City Department of Education] public school system” that “address student populations that require intensive support due to their disability classifications.” Admin. R. at 708. 2 R.Z. began attending iBRAIN in March 2020. The placement for the period before the 2021–2022 school year is not an issue in this appeal.

3 services that were recommended in March 2021, but it altered its recommendations regarding

assistive technology services and reclassified R.Z’s eligibility category from traumatic brain injury

to multiple disabilities.

In October 2021, Appellants, pursuant to administrative procedures, filed a due process

complaint alleging that Appellees denied R.Z. a FAPE for the 2021–2022 school year and seeking

reimbursement of costs associated with placing R.Z. at iBRAIN. As relevant to this appeal,

Appellants argued that R.Z. did not receive a FAPE because: (1) Appellants were denied the

ability to meaningfully participate in the IEP process when Appellees held the August 2021 IEP

meeting without them present and without providing them proper notice of that meeting;

(2) Appellees failed to consider the report of Dr. Isabel Rodriguez, who evaluated R.Z. in

connection with a separate educational proceeding after the March 2021 IEP meeting but before the

August 2021 IEP meeting; (3) Appellees incorrectly changed R.Z.’s eligibility classification from

traumatic brain injury to multiple disabilities; and (4) the Horan School was not an appropriate

school placement for R.Z. An impartial hearing officer (“IHO”) agreed with Appellants,

determining that Appellees had denied R.Z. a FAPE, iBRAIN was an appropriate school location,

and Appellants were entitled to reimbursement for the cost of tuition and related services at

iBRAIN. Appellees appealed to the New York State Department of Education’s Office of State

Review, and, in April 2022, a State Review Officer (“SRO”) reversed the IHO’s decision,

concluding that R.Z. had received a FAPE for the 2021–2022 school year and denying Appellants’

request for reimbursement.

Appellants then appealed to a federal district court, seeking review of the SRO’s decision

that R.Z. received a FAPE and that Appellants were not entitled to reimbursements costs. After

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