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K. M., Individually and on Behalf of M. M. and S. M., et al. v. Eric L. Adams, Mayor of the City of New York, et al.

Paid petition · United States Court of Appeals for the Second Circuit, No. 20-4128 · judgment August 31, 2022


Certiorari denied · June 26, 2023
Pre-decision estimate: 10% cert probability (95% interval 7%–15%)

Before the decision, about 2.5× the 4.1% base rate. The model weighted this up for counsel who has won certiorari before, a Second Circuit decision below, and a circuit split argued in the petition.

Question presented

  1. The Individuals with Disabilities Education Act (“IDEA”) requires, with certain exceptions, the exhaustion of administrative remedies before a judicial challenge under the Act may be brought. Is this exhaustion requirement jurisdictional, or rather, is it a claim-processing rule that must be raised as an affirmative defense that may be waived?

Counsel of record

For petitioner
Melissa Arbus Sherry
Latham & Watkins LLP

For respondent
Jonathan Griffin Brush
Rogers, Morris & Grover, L.L.P.

Case

Conference history
Distributed for 2 conferences

Linked docket
22A464

Proceedings

  1. Jun 26 2023
    Petition DENIED.
  2. Jun 06 2023
    DISTRIBUTED for Conference of 6/22/2023.
  3. Jun 05 2023
    Reply of petitioners K. M., Individually and on behalf of M. M. and S. M. filed. (Distributed)
  4. May 22 2023
    Brief of respondent New York State Department of Education in opposition filed.
  5. May 22 2023
    Brief of respondents Eric L. Adams, David C. Banks, New York City Department of Education in opposition filed.
  6. May 22 2023
    Brief of respondent Austin Independent School District in opposition filed.
  7. May 22 2023
    Brief of respondents Ashford Board of Education, et al. in opposition filed.
  8. May 22 2023
    Letter from Middletown Township Public Schools, West Orange Public Schools, Cherry Hill Public Schools and Readington Township Public Schools received.
  9. Apr 20 2023
    Response Requested. (Due May 22, 2023)
  10. Apr 19 2023
    DISTRIBUTED for Conference of 5/11/2023.
  11. Apr 03 2023
    Waiver of right of respondents Addison Central School District, et al. to respond filed.
  12. Mar 31 2023
    Waiver of Ashford Board of Education, et al. of right to respond not accepted for filing. (March 31, 2023)
  13. Mar 31 2023
    Waiver of right of respondents Ashford Board of Education, et al. to respond filed.
  14. Mar 31 2023
    Supplemental brief of petitioners K. M., Individually and on Behalf of M. M. and S. M., et al. filed.
  15. Mar 28 2023
    Waiver of right of respondent New York State Department of Education to respond filed.
  16. Mar 28 2023
    Waiver of right of respondent Pennsylvania Department of Education to respond filed.
  17. Mar 08 2023
    Waiver of right of respondents Eric L. Adams, David C. Banks, New York City Department of Education to respond filed.
  18. Mar 07 2023
    Waiver of right of respondents Middletown Township Public Schools, West Orange Public Schools, Cherry Hill Public Schools and Readington Township Public Schools to respond filed.
  19. Mar 06 2023
    Waiver of right of respondent Austin Independent School District to respond filed.
  20. Feb 27 2023
    Petition for a writ of certiorari filed. (Response due April 3, 2023)
  21. Nov 30 2022
    Application (22A464) granted by Justice Sotomayor extending the time to file until February 27, 2023.
  22. Nov 22 2022
    Application (22A464) to extend the time to file a petition for a writ of certiorari from December 29, 2022 to February 27, 2023, submitted to Justice Sotomayor.