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Leonarda Bautista, Individually and as Parent and Natural Guardian of A. B. v. Kamar H. Samuels, Chancellor of the New York City Department of Education, et al.

Paid petition · United States Court of Appeals for the Second Circuit, No. 25-945 · judgment February 27, 2026


Certiorari denied · October 5, 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, 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. At an impartial hearing seeking reimbursement for a private placement under the Individuals with Disabilities Education Act, does a Parent waive her right to seek transportation funding when her attorney makes a misstatement as to the relief sought, despite making a claim for transportation in the Due Process Complaint, presenting evidence to support the claim, and never abandoning the claim?

  3. Under the Burlington/Carter test to determine a parent’s entitlement to public funding of a private placement, is the parent held to a higher standard of proof under Prong II than the school district is held under Prong I, or a lower standard of proof?

Counsel of record

For petitioner
Rory J. Bellantoni
Liberty & Freedom Legal Group

For respondent
—

Case

Subject area
Civil Rights (estimated from the questions presented, in the Supreme Court Database’s categories)

Conference history
Distributed for 1 conference

Order
Order list, October 5, 2026 · Certiorari denied

Proceedings

  1. Oct 05 2026
    Petition DENIED.
  2. Sep 02 2026
    DISTRIBUTED for Conference of 9/28/2026.
  3. Jul 08 2026
    Petition for a writ of certiorari filed. (Response due August 20, 2026)