J.M. v. New York City Department of Education
This case involves parents (J.M. and N.M.) and their child (L.M.) seeking tuition reimbursement from the New York City Department of Education (DOE) for L.M.'s private school tuition at the Rebecca School for the 2011-12 school year. L.M., diagnosed with Pervasive Developmental Disorder and classified with Autism, was offered a Free Appropriate Public Education (FAPE) by the DOE, including an Individualized Education Program (IEP) and placement at the Hungerford School. The parents rejected the placement and unilaterally re-enrolled L.M. privately. The court, deferring to the State Review Officer's (SRO) decision over the Impartial Hearing Officer's (IHO) decision, found that the IEP's procedural deficiencies regarding the transition plan did not deprive L.M. of a FAPE when the IEP was viewed as a whole. Furthermore, the court determined that the parents' objections to the Hungerford School (size, noise, socialization concerns) were impermissibly speculative and did not demonstrate that Hungerford could not implement the IEP. Consequently, the court denied the plaintiffs' motion for summary judgment and granted the defendant's cross-motion for summary judgment, concluding that the DOE had offered L.M. a FAPE.