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Avoletta et al. v. Torrington et al.

March 31, 2008

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

PETER AVOLETTA, ET AL. :

v. : No. 3:07CV841(AHN)

CITY OF TORRINGTON, ET AL. :

RULING ON PENDING MOTIONS

The plaintiffs, Joanne Avoletta (“Mrs. Avoletta”) and her

two sons, Peter Avoletta (“Peter”) and Matthew Avoletta

(“Matthew”), bring this action asserting claims under (1) the

Connecticut Constitution, (2) the Individuals with Disabilities

Education Act (“IDEA”), 20 U.S.C. §§ 1400-1485, as amended by

IDEIA, and Connecticut statutes and regulations, (3) Section 504

of the Rehabilitation Act (“Section 504”), 29 U.S.C. § 794, (4)

the Americans with Disabilities Act (“ADA”), 42 U.S.C. § 12101,

et seq., (5) the Civil Rights Act, 42 U.S.C. § 1983, as well as

state-law claims for (6) intentional spoilation of evidence, (7)

fraudulent concealment of evidence, and (8) negligent infliction

of emotional distress.

The defendants are the City of Torrington (“City”), the

Torrington Board of Education (“Board”), and the following

persons in both their individual and official capacities: Paul

Cavagnero, Chairman of the Torrington Board of Education, Dr.

Edward Kavle, the medical advisor for the Torrington public

schools, Veronica LeDuc, the Principal of the Torrington High

School, Judith Babcock, the Director of Student Services for the

Torrington public schools, Dr. Joann Brogis, the former guidance

counselor for the Torrington public schools, and David Bascetta,

the director of facilities for the Torrington public schools.

Pending before the court are the defendants' motions to

dismiss [docs. ## 45 & 46] pursuant to Fed. R. Civ. P. 12(b)(1)

and (6). The defendants assert that the court does not have

subject matter jurisdiction because the plaintiffs failed to

exhaust their administrative remedies under the IDEA. The

defendants also assert numerous grounds to dismiss the complaint

for failure to state a claim on which relief may be granted.

Also pending is the plaintiffs' motion to remand [doc. # 20].

For the following reasons, the motions to dismiss are

GRANTED in part and DENIED in part and the motion to remand is

also GRANTED in part and DENIED in part.

FACTS

The gist of the plaintiffs' claims is that the defendants

failed to provide Peter and Matthew a free appropriate public

education (“FAPE”) in a safe school setting without

discrimination due to disabilities that were caused by the

defendants' failure to properly maintain the Torrington public

school buildings. They assert that the defendants' negligent

failure to properly maintain the middle school caused it to

sustain water damage from leaks in the roof, mold and bacterial

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growth, high levels of moisture in the indoor air, and poor

circulation of air. They contend that the defendants' negligent

failure to properly maintain the high school resulted in asbestos

problems, leaks in the roof and windows, minimal ventilation

rates, and broken air handlers. According to the plaintiffs,

these conditions caused Peter to suffer irreversible lung disease

and Matthew to suffer moderate to severe chronic allergies and

asthma, thereby rendering both of them disabled and requiring

special education services. The defendants failed to provide

those services and thereby deprived both children of their rights

to a FAPE.

The plaintiffs allege that beginning with the 2003-2004

school year and continuing through the 2005-2006 school year,

they repeatedly invoked their rights pursuant to the IDEA and

Connecticut and federal statutes by requesting the defendants

hold planning and placement team (“PPT”) meetings for both

children. The defendants, however, refused some of their

requests for PPT meetings, refused to identify both children as

eligible under the IDEA for special education and related

services due to their health impairments, and directed them to

proceed under Section 504 rather than under the IDEA.

More specifically, Peter attended Torrington public schools

from August 1999 through the end of the 2002-2003 school year.

After he was diagnosed in 2003 with irreversible lung disease,

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his physician advised him to remain at home for the 2003-2004

school year. In August 2003 Mrs. Avoletta asked the Board to

hold a PPT meeting to identify Peter under the IDEA as “other

health impaired” and eligible for special services and she also

requested a Section 504 meeting. The Board held meetings only

under Section 504, not under the IDEA. In October 2003 the Board

identified Peter as eligible for accommodations pursuant to

Section 504 and provided him with homebound instruction for the

2003-2004 school year.

Mrs. Avoletta requested the Board place Peter in an out of

district public or private school for the 2004-2005 school year.

When the defendants refused, Mrs. Avoletta unilaterally placed

him in a private high school in Waterbury, Connecticut.

From October 2003 to October 2005 the Board held numerous

Section 504 meetings regarding Peter's education plan. Then, in

October 2005 the Board denied the request to place Peter in an

out of district school. In November 2005 Mrs. Avoletta requested

a Section 504 due process hearing for Peter. The hearing was

scheduled for April 2006, but it was cancelled by Mrs. Avoletta.

In addition, from November 2003 to May 2004 the Board held

four PPT meetings regarding Peter's eligibility under the IDEA.

The PPT process ended in May 2004 when the Board denied Mrs.

Avoletta's request to identify Peter as eligible for special

services under the IDEA.

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During this time period Mrs. Avoletta unilaterally continued

to send Peter to private school and the Board denied her repeated

requests for reimbursement of his private school tuition and

associated costs. Peter graduated from that private high school

in June 2006 and now attends college.

Matthew was 15 at the time this action was commenced. He

attended Torrington public schools from August 1997 to June 2003.

In the spring of 2003 Mrs. Avoletta requested the Board hold a

PPT meeting to identify him as other health impaired and

requiring special services under the IDEA and Section 504. The

Board denied her request. In August 2003, on the advice of

Matthew's physician, Mrs. Avoletta notified the Board that she

would not allow Matthew to attend Torrington Middle School and

that she was placing him in a private school. The Board then

held the first of several Section 504 meetings to consider

whether he was eligible for accommodations as a child with a

disability. After the Board determined that he was not eligible

under Section 504, Mrs. Avoletta unilaterally placed him in a

private school in Waterbury. From that time until October 2005

the Board held seven additional Section 504 meetings, but it

continued to find that Matthew was not eligible for

accommodations under Section 504 and refused to place him in an

out of district public or private school.

In November 2005 Mrs. Avoletta requested the defendants hold

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a due process hearing under Section 504 for Matthew. The hearing

was held and on April 3, 2006 the hearing officer found that he

was not eligible for accommodations under Section 504.

During this same time period, Mrs. Avoletta also requested

PPT meetings to have Matthew identified under the IDEA as other

health impaired. The Board denied all but three of her requests

for PPT meetings. The last PPT meeting was held in September

2004 at which time the Board refused to identify Matthew as

eligible for special education under the IDEA and directed Mrs.

Avoletta to pursue her rights under Section 504.

Mrs. Avoletta did not ask the defendants to place Matthew in

an out of district school for the 2006-2007 school year or to

identify him as eligible for special accommodations because doing

so would have been futile.

Mrs. Avoletta continued to unilaterally send Matthew to

private school. She requested the defendants reimburse her for

Matthew's tuition and costs, but the defendants refused her

requests.

In addition to pursuing these claims with the Board, in

September 2004 Mrs. Avoletta filed a discrimination complaint

against the defendants with the United States Office of Civil

Rights, the agency responsible for enforcing Section 504 and the

ADA, regarding Peter's treatment. In October 2005, the Office

found that there was insufficient evidence to prove that the

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Board had failed to comply with the requirements of Section 504

requiring special education and related services to meet Peter's

needs. The office declined Mrs. Avoletta's request to reconsider

its decision in April 2006.

In March 2006 Mrs. Avoletta filed a discrimination complaint

with the United States Office of Civil Rights regarding Matthew's

treatment. In July 2006 the Office determined that it was

“unable to accept any of the complaint issues alleging

discrimination on the basis of disability for investigation.”

The plaintiffs allege that they exhausted their

administrative remedies for Peter and Matthew pursuant to the

IDEA and Section 504 for all relevant school years.

This action was filed in May 2007 in the Connecticut

Superior Court and was removed by the defendants to this court.

STANDARD OF REVIEW

In cases such as this, where a Rule 12(b)(1) motion to

dismiss based on lack of subject matter jurisdiction is combined

with a Rule 12(b)(6) motion, the court must decide the

jurisdictional question first because disposition of a Rule

12(b)(6) motion is a decision on the merits and thus an exercise

of jurisdiction. Rhulen Agency, Inc. v. Alabama Ins. Guar.

Ass'n, 896 F.2d 674, 678 (2d Cir. 1990) (noting that a motion to

dismiss for failure to state a claim may be decided only after

finding subject matter jurisdiction); Magee v. Nassau County Med.

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Ctr., 27 F. Supp 2d 154, 158 (E.D.N.Y. 1998).

To resolve disputed issues of fact relating to subject

matter jurisdiction in a Rule 12(b)(1) motion, the court may

consider evidence beyond the pleadings, including affidavits and

other evidence submitted by the parties. Flores v. Southern Peru

Copper Corp., 414 F.3d 233, 235 n.30 (2d Cir. 2003).

The plaintiff, as the party asserting subject matter

jurisdiction, has the burden of establishing that it exists by a

preponderance of the evidence. Malik v. Meissner, 82 F.3d 560,

562 (2d Cir. 1996).

DISCUSSION

The defendants move pursuant to Fed. R. Civ. P. 12(b)(1) to

dismiss the plaintiffs' claims under the Connecticut Constitution

(count one), the IDEA and Connecticut statutes and regulations

(count two), Section 504 (count three),1 the ADA (count four),2

1 Section 504 prohibits discrimination on the basis of a disability “under any program or activity receiving Federal financial assistance.” 29 U.S.C. § 794. Under the federal regulations that implement Section 504, the denial of a FAPE to a disabled student can constitute disability discrimination. 34 C.F.R. § 104.33(a); J.D. ex rel. J.D. v. Pawlet Sch. Dist., 224 F.3d 60, 70-71 (2d Cir. 2000). While Section 504 addresses, inter alia, discrimination against disabled students, the IDEA addresses inappropriate special education services. See S.W. v. Warren, 528 F. Supp 2d 282, 289 (S.D.N.Y. 2007). 2 Title II of the ADA extends Section 504's prohibition against discrimination on the basis of disability to all programs and services provided by state and local governments. The enforcement provision of the ADA incorporates the enforcement provision of the Rehabilitation Act and both acts are interpreted uniformly. 28 C.F.R. § 35.103.

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42 U.S.C. § 1983 (count five), as well as the claim for negligent

infliction of emotional distress (count eight). They maintain

that all of these claims relate to the alleged denial of Peter's

and Matthew's right to a free appropriate public education and,

as such, are subject to IDEA's exhaustion requirements. They

claim that the plaintiffs' failure to exhaust the IDEA's

administrative remedies deprives the court of subject matter

jurisdiction.3

The defendants also move pursuant to Rule 12(b)(6) to

dismiss the plaintiffs' claims on the grounds that they are

barred by the doctrine of res judicata and assert numerous

arguments supporting dismissal of all the claims, including the

state-law claims, on grounds of, inter alia, sovereign and

municipal immunity.

Because the defendants have raised the issue of the court's

3 The plaintiffs contend that their claim for denial of a FAPE under the state constitution (count one) is not subject to exhaustion. However, it is well settled that a plaintiff cannot escape the IDEA's exhaustion requirement by artfully drafting a complaint avoiding the IDEA where the relief sought is available under the IDEA. E.g., Hope v. Cortines, 872 F. Supp. 14, 17 (E.D.N.Y. 1995), aff'd, 69 F.3d 687 (2d Cir. 1995); DiStiso v. Town of Wolcott, No. 3:05cv1910(PCD), 2006 WL 3355174, at *4 (D. Conn. Nov. 17, 2006). Moreover, it appears that a plaintiff does not have a private right of action under the Connecticut Constitution for injuries for which the legislature has provided a reasonably adequate statutory remedy. Kelley Prop. Dev. Inc, v. Town of Lebanon, 226 Conn. 314, 339 (1993). For this reason, the plaintiffs' claims under the Connecticut Constitution could not be sustained even if they had exhausted their administrative remedies under the IDEA.

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subject matter jurisdiction, that issue must be decided first.

I. Rule 12(b)(1) - Lack of Subject Matter Jurisdiction

The defendants maintain that the court does not have subject

matter jurisdiction over the claims alleging denial of a FAPE

because the plaintiffs did not exhaust the IDEA's administrative

remedies. The court agrees.

Under the IDEA, states that receive federal funds must

provide disabled children a FAPE tailored to the unique needs of

each particular child in the least restrictive appropriate

environment. 20 U.S.C. §§ 1401(8), 1412(a); Polera v. Bd. of

Educ. of Newburgh, 288 F.3d 478, 481 (2d Cir. 2002). The IDEA

gives parents of disabled children extensive procedural and

substantive safeguards to ensure that their children receive a

FAPE. 20 U.S.C. § 1415. One of those safeguards is the

requirement that the educational needs of a disabled child be set

forth at least annually in an individualized education program

(“IEP”) developed by a Planning and Placement Team (“PPT”)

composed of, inter alia, parents, teachers, and school officials.

20 U.S.C. §§ 1414(d)(4)(A)(1) & (1)(B). If a dispute arises

between a school board and a parent as to a child's IEP, either

party may request an impartial due process hearing conducted by

the state educational agency. 20 U.S.C. § 1415(b)(6).

Thereafter, either party may bring a civil action in state or

federal court for judicial review of the findings and decision of

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the due process hearing. 20 U.S.C. § 1414(i)(2)(A). But as the

IDEA statute clearly states, before a party may file a civil

action under the IDEA, the Constitution, the ADA, Section 504, or

other laws protecting the rights of children with disabilities,

the statutorily required impartial due process hearing “shall be

exhausted.” 20 U.S.C. § 1415(l).

To comply with the IDEA, Connecticut has enacted a series of

statutes and regulations governing the provision of a FAPE to

children who require special education and related services and

the administrative process that must be followed. Conn. Gen.

Stat. § 10-76(a), et seq.; Conn. Agency Regs. § 10-76a-1, et seq.

Under these statutes and regulations, the local board of

education must accept and process a referral from, inter alia, a

child's parent to determine a child's eligibility for special

education and related services. Each child who has been referred

for such a determination must be evaluated by a PPT. If the PPT

determines that the child is eligible for special education and

related services, the PPT must develop an IEP. Parents who are

not satisfied with the IEP may request, in writing, a hearing by

an impartial hearing officer regarding the proposal or refusal to

initiate or change the identification, evaluation, or educational

placement of the child or the provision of a FAPE to the child.

The hearing officer must issue written findings of fact and

conclusions of law. The decision may be appealed to federal or

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state court.

Unless these administrative procedures are exhausted, an

aggrieved parent may not seek redress in federal or state court

to enforce any rights, procedures, and remedies available under,

inter alia, the IDEA, the ADA, Section 504, and 42 U.S.C. § 1983,

even though these statutes do not have an exhaustion requirement

for claims unrelated to the IDEA. E.g., J.S. ex rel. N.S. v.

Attica Cent. Schs., 386 F.3d 107, 112 (2d Cir. 2004); Polera, 288

F.3d at 480. As the Second Circuit explained, the IDEA's

exhaustion requirement “was intended to channel disputes related

to the education of disabled children into an administrative

process that could apply administrators' expertise in the area

and promptly resolve grievances,” “prevents courts from

undermining the administrative process,” and “permits an agency

to bring its expertise to bear on a problem as well as to correct

its own mistakes.” Polera, 288 F.3d at 487 (quoting Heldman ex

rel. T.H. v. Sobol, 962 F.2d 148, 159 (2d Cir. 1992)).

A. The Administrative Process in this Case

The defendants assert that the plaintiffs never requested a

due process hearing as required by the IDEA for either Matthew or

Peter regarding their eligibility determinations, evaluations,

out of district placement, or the alleged failure to provide a

FAPE. The plaintiffs do not dispute this assertion, but claim

that they exhausted their IDEA administrative remedies “to the

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fullest extent possible before the defendants directed [them] to

proceed under Section 504 and [they] pursued their Section 504

remedies to the conclusion of a due process hearing prior to

seeking redress in court.” According to the plaintiffs, the

administrative process through which they asserted their rights

under Section 504 satisfies the IDEA's exhaustion requirements,

especially because the defendants directed them to proceed under

Section 504. They also claim that their efforts to obtain

redress by filing complaints with the Connecticut Office of

Protection & Advocacy for Disabled Persons and the United States

Office of Civil Rights also satisfies IDEA's exhaustion

requirements. The court disagrees.

As noted, there is no dispute that Mrs. Avoletta never

requested due process hearings under the IDEA for either Peter or

Matthew: she did not request an IDEA due process hearing after

the defendants refused her numerous requests to conduct PPT

meetings to identify Peter and Matthew as other health impaired

and eligible for special education under the IDEA; nor did she

request an IDEA due process hearing after the defendants

eventually held PPT meetings for Peter and Matthew, but

determined that they were not disabled under the IDEA and not

eligible for special services. Because she never requested a due

process hearing under the IDEA to challenge any of the

defendants' actions or determinations, she did not exhaust the

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IDEA's administrative remedies.

Moreover, Mrs. Avoletta's failure to request due process

hearings is not excused by her efforts to obtain accommodations

for Peter and Matthew under Section 504, or by requesting Section

504 “due process hearings” to challenge the defendants'

determination that Peter and Matthew were not disabled, or by

participating in one Section 504 “due process hearing” for

Matthew. And her failure to request due process hearings under

the IDEA is also not excused by the complaints she filed with the

Connecticut educational agencies and the United States Office of

Civil Rights against the City and Board alleging discrimination

under Section 504.

It is the exhaustion of the IDEA's administrative

procedures, not procedures under Section 504, that is the

prerequisite for bringing an action in federal or state court

alleging the denial of a FAPE under the IDEA, Section 504, the

ADA, Section 1983, or any other cause of action. Myslow v. New

Milford Sch. Dist., 3:03cv496(MRK), 2006 WL 473735, at *10 n.2

(D. Conn. Feb. 28, 2006); 20 U.S.C. § 1415(l).

Indeed, the plain language of the IDEA and Second Circuit

case law dictate that IDEA exhaustion is required whenever a

plaintiff seeks relief under any federal or state law if the

relief sought is the same as the relief that would be available

under the IDEA. 20 U.S.C. § 1415(l); Polera, 288 F.3d at 483;

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Hope v. Cortines, 872 F. Supp. at 21. Thus, because the relief

the plaintiffs seek under Section 504, the ADA, the Connecticut

Constitution and statutes, and Section 1983, is relief that is

also available under the IDEA, they were required to exhaust

their administrative remedies under the IDEA even though the

other causes of action do not require exhaustion for claims

unrelated to the IDEA. See Polera, 288 F.3d at 488.

The plaintiffs' failure to comply with the IDEA's due

process requirement not only deprived the defendants of an

opportunity in the first instance to correct and remedy any

shortcomings in the educational programs for Peter and Matthew

and prevented the full exploration of technical and other issues

by educational experts, it also deprived this court of the

considered opinions and factual findings of educational experts

as well as an administrative record, all of which the court would

need to review and consider when determining whether the

plaintiffs' rights were violated. See Polera, 288 F.3d at 486-88

(quoting Heldman ex rel. v. Sobol, 962 F.2d 148, 159 (2d Cir.

1992)); Garro v. State of Conn., 23 F.3d 734, 738 (2d Cir. 1994).

It stands to reason that because the IDEA and Section 504 address

different injuries and require different proof, J.D. ex rel. J.D.

v. Pawlet Sch. Dist., 224 F.3d 60, 70 (2d Cir. 2000) (citing

Monahan v. State of Nebraska, 687 F.2d 1164, 1170-71 (8th Cir.

1982)) (noting that a court's conclusion that an incorrect

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evaluation was made and a different placement was required under

the IDEA is not the same as a conclusion that a disabled child,

either because of bad faith or gross misjudgment, was

discriminated against solely by reason of his disability in

violation of Section 504), an administrative record of a Section

504 proceeding would not provide an adequate record for the court

to review in determining whether the defendants incorrectly

evaluated Peter and Matthew and denied them a FAPE.

In sum, because the plaintiffs failed to request due process

hearings as required by IDEA, they did not exhaust their

administrative remedies.

B. Futility

The plaintiffs' claim that it would have been futile for

them to seek relief through the IDEA administrative process is

without merit. Although the plaintiffs correctly assert that the

failure to exhaust the IDEA's administrative remedies may be

excused where doing so would have been futile, e.g., Hope v.

Cortines, 872 F. Supp. at 22, futility means more than a failure

to provide services. Polera, 288 F.3d at 409.

To show futility, a plaintiff must demonstrate that

“adequate remedies are not reasonably available or that the

wrongs alleged could not or would not have been corrected by

resort to the administrative hearing process.” J.G. v. Bd. of

Educ. of Rochester City Sch. Dist., 830 F.2d 444, 447 (2d Cir.

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1987). In other words, the exhaustion requirement is excused by

the futility doctrine in cases where pursuing the IDEA's

administrative process would leave the party without an adequate

remedy. Coleman v. Newburgh Enlarged City Sch. Dist., 503 F.3d

198, 205 (2d Cir. 2007). An adequate remedy means relief for

“the events, conditions, or consequences of which the person

complains, [even if] not necessarily relief of the kind the

person prefers.” Polera, 288 F.3d at 488. Thus, if the IDEA

administrative process offers a remedy, even if not the preferred

remedy, for the ills of which a plaintiff complains, the

plaintiff may not ignore the administrative process then later

sue under a different statute or theory. Id. at 483. The burden

of demonstrating futility rests with the party seeking to avoid

the exhaustion requirement. Id. at 489 n.8.

Here, unlike cases where the Second Circuit has held that

the futility exception is applicable, this case does not involve

systemic violations that were not directed at any individual

child, nor is it one in which a hearing officer was powerless to

correct the alleged violations. See J.S. ex rel N.S. v. Attica

Cent. Schs., 386 F.3d at 113 (citing numerous cases where

exhaustion was futile in that the “problems could not have been

remedied by administrative bodies because the framework and

procedures for assessing and placing students in appropriate

educational programs were at issue, or because the nature and

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volume of complaints were incapable of correction by the

administrative hearing process”).

To the contrary, the dispute here -- the defendants' refusal

to identify Peter and Matthew as disabled and to provide them

with special education services -- is precisely the kind of

dispute to which the IDEA's administrative scheme is addressed

and is one that a due process hearing officer had the power to

remedy by providing the relief sought –- out of district

placement –- if the hearing officer determined that the children

were eligible for such placement.

The fact that the plaintiffs believed that the relief they

sought was not likely to be awarded at the administrative level

does not mean that resort to the IDEA's administrative procedures

would have been futile. As the Second Circuit has noted, the

futility exception does not apply where a plaintiff merely

chooses not to pursue the remedies that were available at the

administrative level. Polera, 288 F.3d at 490. Disabled

students “should not be permitted to 'sit on' live claims and

spurn the administrative processes that could provide the

educational services they seek, then later sue for damages.” Id.

Condoning such conduct would frustrate the IDEA's carefully

crafted process for the prompt resolution of grievances. . . .”

Id.

Thus, where, as here, there was a fully effective

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administrative remedy available, but was not pursued, the

futility exception does not apply. Id.

C. Waiver

There is also no merit to the plaintiffs' conclusory

assertion that the defendants' conduct in continuously rejecting

the plaintiffs' efforts to proceed under the IDEA and directing

them to proceed under Section 504 constituted a waiver of the

exhaustion requirement. Even assuming that the plaintiffs had

sustained their burden of providing evidence to support a waiver,

this defense has not been recognized in the Second Circuit.

While the Seventh Circuit has held that failure to exhaust

under the IDEA is not a jurisdictional bar, but is only an

affirmative defense that is subject to waiver, Mosely v. Bd. of

Educ. of City of Chicago, 434 F.3d 527, 532-33 (7th Cir. 2006),

the Second Circuit has “yet to reach a clear conclusion on this

question.” Paese v. Hartford Life & Accident Ins. Co., 449 F.3d

435, 444 n.2 (2d Cir. 2006). In fact, in Paese and more recently

in Coleman v. Newburgh Enlarged City School District, 503 F.3d

198 (2d Cir. 2007), the Second Circuit acknowledged that it has

routinely held that the IDEA's exhaustion requirement is a

jurisdictional but, while it has also referred to the IDEA's

exhaustion requirement as a “non-exhaustion defense,” it has

never decided whether the IDEA's exhaustion requirement was

subject to waiver. Paese, 449 F.3d at 444 n.2; Coleman, 503 F.3d

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at 203-04. Nonetheless, the court in Coleman, as it did in

Paese, concluded once again that it did not need to decide the

issue because a waiver defense was not tenable in the case before

it. 503 F.3d at 203-04; see also Handberry v. Thompson, 446 F.3d

52, 60 (2d Cir. 2006) (on rehearing) (noting that it had not yet

ruled on whether the IDEA's exhaustion requirement is subject to

waiver, but noting its holding that “absent an applicable

exception, a plaintiffs' failure to exhaust IDEA's administrative

remedies deprived the court of subject matter jurisdiction”).

Until the Second Circuit rules otherwise, the law in this

circuit is that failure to exhaust is a jurisdictional bar, not

an affirmative defense that is subject to waiver. Accordingly,

the plaintiffs' waiver claim is unavailing.

Because the plaintiffs did not pursue or exhaust the

administrative remedies required by the IDEA and because there is

no applicable exception to the exhaustion requirement, this court

does not have subject matter jurisdiction to rule on the

appropriateness of the Board's decision that Peter and Matthew

were not disabled and were not entitled to placement in an out of

district school. See, e.g., Handberry v. Thompson, 446 F.3d at

60.

Accordingly, the defendants' Rule 12(b)(1) motions to

dismiss the plaintiffs' claims under the Connecticut

Constitution, Connecticut statutes and regulations, the IDEA, the

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ADA, Section 504, 42 U.S.C. § 1983, and for negligent infliction

of emotional distress4 as asserted in counts one, two, three,

four and eight of the complaint, are granted.

II. Rule 12(b)(6) Motion to Dismiss

The defendants have also asserted numerous grounds to

dismiss the plaintiffs' state-law claims under Rule 12(b)(6).

Although the court has supplemental jurisdiction over these

remaining claims under 28 U.S.C. 1367, the court, as discussed

infra, declines to exercise that jurisdiction now that the

plaintiffs' federal claims have been dismissed.

Accordingly, the court will not consider or decide the

defendants' claims in support of their Rule 12(b)(6) motion to

dismiss and denies this portion of the motion without prejudice.

III. Motion to Remand

The plaintiffs have moved pursuant to 28 U.S.C. § 1447 to

remand this case to the Connecticut Superior Court. They assert

that this court lacks subject matter jurisdiction over their

state constitutional claims because they raise novel and complex

4 The negligent infliction of emotional distress claim asserted in count eight is nothing more than a reformulation of the plaintiffs' statutory claims (i.e., the plaintiffs allege that the defendants “negligently inflicted emotional distress on the plaintiffs by failing to provide a free appropriate public education to Peter and Matthew in a safe school setting without discrimination against them due to their disabilities during all relevant years”) and thus is also subject to the IDEA's exhaustion requirement. See DiStiso v. Town of Wolcott, 2006 WL 3355174, at * 4; 20 U.S.C. § 1415(l).

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issues of state law and they substantially predominate over the

federal claims. There is no merit to this assertion.

By virtue of the four federal causes of action alleged in

the complaint, i.e., the IDEA, Section 504, the ADA, and 42

U.S.C. § 1983, this court has original jurisdiction pursuant to

28 U.S.C. §§ 1331 and 1343(a)(3) and the action was properly

removed under 28 U.S.C. § 1441(a). Accordingly, remand is not

authorized under 28 U.S.C. § 1447. Indeed, because this court

has original jurisdiction over the federal claims, it has no

discretion to remand them. Nelson v. City of Rochester, 492 F.

Supp 2d 282, 286 (W.D.N.Y. 2007) (citing Green v. Ameritrade,

Inc., 279 F.3d 590, 596 (8th Cir. 2002)); see also 16 Moore's

Federal Practice § 107.14[6][b]. Further, it would not be

appropriate to remand the state-law claims even if the plaintiffs

had moved under 28 U.S.C. § 1441(c) because those claims are not

separate and independent from the federal claims. See Hinson v.

Norwest Fin. S.C., Inc., 239 F.3d 611, 616 (4th Cir. 2001)

(holding that where the state and federal claims are not separate

and independent from each other, § 1441(c) simply has no bearing

on the issue of remand). In fact, the federal and state-law

claims alleged in the complaint arise out of the same facts so

the court has supplemental jurisdiction over the state-law claims

under 28 U.S.C. § 1367 and removal of the entire action was

proper. Nelson v. City of Rochester, 492 F. Supp 2d at 286.

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Thus, the plaintiffs' motion to remand the action is denied.

Nonetheless, to the extent the plaintiffs' motion can be

construed as asking the court to decline supplemental

jurisdiction and remand the state-law claims, the motion is

granted. In fact, because the court has dismissed all claims

over which it had original jurisdiction, it must reassess its

jurisdiction. Motorola Credit Corp. v. Uzan, 388 F.3d 39, 56 (2d

Cir. 2004) (“[O]ur Court has held, as a general proposition, that

‘if [all] federal claims are dismissed before trial ... the state

claims should be dismissed as well.’”) (quoting Castellano v. Bd.

of Trustees, 937 F.2d 752, 758 (2d Cir. 1991)).

When all of a plaintiffs' federal claims have been

dismissed, a district court can decline to exercise supplemental

jurisdiction over the state law claims pursuant to 28 U.S.C. §

1367(c) if it determines that exercising supplemental

jurisdiction would not promote economy, convenience, fairness,

and comity. Itar-Tass Russian News Agency v. Russian Kurier,

Inc., 140 F.3d 442, 446 (2d Cir. 1998). In this case, permitting

the parties to litigate the remaining state-law claims in this

court now that all the federal claims have been dismissed would

not promote economy, convenience, fairness, and comity. Indeed,

doing so would amount to what has been described as “allowing a

federal tail to wag what is in substance a state dog.” Borough

of West Mifflin v. Lancaster, 45 F.3d 780, 787 (3d Cir. 1995).

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Moreover, the interests of federalism and comity favor litigating

the state-law issues, especially those involving sovereign and

municipal immunity, in state court. See Valencia ex rel. Franco

v. Lee, 316 F.3d 299, 306 (2d Cir. 2003); Marcus v. AT&T Corp.,

138 F.3d 46, 57 (2d Cir. 1998) (“In general, where the federal

claims are dismissed before trial, the state claims should be

dismissed as well.”).

Accordingly, the court declines to exercise supplemental

jurisdiction pursuant to 28 U.S.C. § 1367(c) and remands the

remaining state-law claims to the Connecticut Superior Court.

CONCLUSION

For the foregoing reasons, the defendants' motions to

dismiss [docs. ## 45 & 46] are GRANTED in part and DENIED in

part. In so far as the motions seek to dismiss the plaintiffs'

claims under the Connecticut Constitution and statutes, the IDEA,

Section 504, the ADA, and for negligent infliction of emotional

distress pursuant to Fed. R. Civ. P. 12(b)(1) for lack of subject

matter jurisdiction, the motion is GRANTED. In so far as the

motions seek dismissal of the remaining state-law claims pursuant

to Fed. R. Civ. P. 12(b)(6), the motion is denied without

prejudice.

The plaintiffs' motion to remand [doc. # 20] is DENIED in

part and GRANTED in part in so far as it asks the court to

decline supplemental jurisdiction and to remand the remaining

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state-law claims to state court.

Accordingly, counts one, two, three, four, five, and eight

of the complaint are dismissed. The Clerk is directed to remand

this action to the Connecticut Superior Court from which it was

removed.

SO ORDERED this 31st day of March, 2008 at Bridgeport,

Connecticut.

/s/____________________________ Alan H. Nevas United States District Judge

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