Jennie Landsman, Individually and as Parent and Natural Guardian of J. L. v. Melissa Aviles-Ramos, Chancellor of the New York City Department of Education, et al.

Under the Individuals with Disabilities Education Act, in order to determine whether the parent of a disabled child is entitled to reimbursement from the local school district for a unilateral placement, local and state administrative officers and courts apply the Burlington/Carter analysis. If the parent prevails on the first two prongs of that test, is there a rebuttable presumption of full reimbursement, which the school district may rebut only by producing evidence showing that the equities do not favor full reimbursement?

Under the Individuals with Disabilities Education Act, when a parent wishes to seek reimbursement for their disabled child’s unilateral placement, they are required to provide the local school district a Ten-Day Notice before withdrawing their disabled student from the public school and unilaterally placing them in a private school. To obtain a reduction of reimbursement for a unilateral placement under Prong III of the Burlington/Carter test on the grounds that the parent failed to comply with the IDEA's ten-day notice requirement, must a school district show that it was harmed by the parent's noncompliance?