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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.

Paid petition · United States Court of Appeals for the Second Circuit, No. 24-2303 · judgment July 30, 2025


Certiorari denied · February 23, 2026
Pre-decision estimate: 3% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

  1. 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?

  2. 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?

Counsel of record

For petitioner
Rory J. Bellantoni
Liberty & Freedom Legal Group

For respondent
Chase Henry Mechanick
New York City Law Department

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Feb 23 2026
    Petition DENIED.
  2. Jan 28 2026
    DISTRIBUTED for Conference of 2/20/2026.
  3. Jan 15 2026
    Waiver of right of respondent Melissa Aviles - Ramos, et al. to respond filed.
  4. Dec 16 2025
    Petition for a writ of certiorari filed. (Response due January 20, 2026)