Skip to main content
Special Education Law
Sign In

Gibson et al. v. Doliver et al.

April 2, 2019

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

EUGENE GIBSON and S.G., : CIVIL ACTION NO. Plaintiffs, : 3:18-CV-01825 (JCH)

v. :

ABBY DOLLIVER, et al., : APRIL 1, 2019 Defendants. :

RULING RE: MOTION TO DISMISS (DOC. NO. 21), MOTION TO DISMISS (DOC. NO. 26), MOTION FOR SUMMARY JUDGMENT (DOC. NO. 29), MOTION TO DENY NOTICE OF REMOVAL ON JURISDICTION (DOC. NO. 38)

I. INTRODUCTION

On October 9, 2018, the plaintiffs, Eugene Gibson (“Gibson”) and his daughter

(“S.G.”), filed this pro se action in Connecticut Superior Court against the defendants,

Abby Dolliver (“Dolliver”), Jamie Bender (“Bender”), and Nakia Hamelett (“Hamelett”).

See generally Complaint (“Compl.”) (Doc. No. 1-1). The Complaint asserts a variety of

federal and state law claims against the defendants, all of which are predicated on the

defendants’ alleged failure to provide S.G. with adequate special education services.

See id. at 4-6, 17.

On November 6, 2018, Dolliver and Bender filed a Notice of Removal, which

Notice indicated that Hamelett had also consented to removing the action from

Connecticut Superior Court to this court. See Notice of Removal (Doc. No. 1) at ¶ 7.

On January 9, 2019, Hamelett moved to dismiss the Complaint under Rules 12(b)(1)

and 12(b)(6) of the Federal Rules of Civil Procedure. See Motion to Dismiss

(“Hamelett’s Mot. to Dismiss”) (Doc. No. 21). That same day, Dolliver and Bender also

moved to dismiss all of the plaintiffs’ claims or, in the alternative, to strike certain

allegations from the Complaint under Rule 12(f) and to order a more definite statement 1

under Rule 12(e). See Motion to Dismiss (“Dolliver & Bender’s Mot. to Dismiss”) (Doc.

No. 26); see also Memorandum of Law in Support of Defendants Abby Dolliver’s and

Jamie Bender’s Motion to Dismiss, Motion to Strike, and/or Motion for More Definite

Statement (“Dolliver & Bender’s Mem.”) (Doc. No. 25) at 10.

On January 29, 2019, this court held an in-person status conference with the

parties, during which time it raised sua sponte the issue of whether the defendants’

removal of the case from state court had properly complied with the rule of unanimity.

See Minute Entry (Doc. No. 32). On February 8, 2019, the defendants jointly filed a

memorandum of law addressing this issue. See Joint Memorandum of Law in Support

of Defendants’ Notice of Removal (“Defs.’ Mem. on Removal”) (Doc. No. 34) at 1.

The plaintiffs have not filed opposition papers to the defendants’ Motions to

Dismiss, even though the defendants notified them of the pending Motions, as required

by Rule 12(a) of the Local Civil Rules of the United State District Court for the District of

Connecticut. See Notice to Self-Represented Litigant Concerning Motion to Dismiss

(Doc. Nos. 22, 24). The plaintiffs have, however, filed various other documents.

Specifically, on January 16, 2019, the plaintiffs filed a Motion for Summary Judgment

(Doc. No. 29). On March 11, 2019, they filed a document titled “Motion to Deny Notice

of Removal Based on Jurisdiction,” which document the court has interpreted as a

motion to remand the case to the Connecticut Superior Court. See Motion to Deny

Notice of Removal on Jurisdiction (“Pls.’ Mot. to Remand”) (Doc. No. 38). Finally, on

March 20, 2019, the plaintiffs submitted a Letter (Doc. No. 39) that largely repeated the

arguments set forth in their Motion for Summary Judgment.

2

For the following reasons, the plaintiffs’ Motion to Remand is denied; the

defendants’ Motions to Dismiss for lack of subject matter jurisdiction are granted; and

the plaintiffs’ Motion for Summary Judgment is denied as moot.

II. BACKGROUND 1

S.G. is 14 years old and currently a 9th grade high school student in the Norwich

Public Schools (“NPS”). See Declaration of Jamie Bender (“Bender’s Decl.”) (Doc. No.

30) at ¶¶ 1, 3; Compl. at 6. Gibson is S.G.’s father. Bender’s Decl. at ¶ 1; Compl. at 5.

Dolliver is the NPS Superintendent, Bender is the NPS Director of Student Services and

Special Education, and Hamelett is a psychologist who was hired by the NPS to

evaluate S.G. in 2018. Bender’s Decl. at ¶ 1.

When S.G. was five years old, the NPS determined that she qualified for special

education services. Id. at ¶ 3. As a result, it created an Individualized Education

Program (“IEP”) for her. Id. In 2018, the NPS ordered a formal Risk Assessment of

S.G. in light of S.G.’s behavior at school. Id. at ¶ 4. The NPS also decided that, until

the Risk Assessment was completed, S.G. should not attend school, but should instead

receive 10 hours per week of homebound instruction. Id.

Although the Complaint in this case is difficult to decipher, all of the plaintiffs’

claims appear to stem from these 2018 changes to S.G.’s IEP. See Compl. at 5

(alleging that the defendants “have broken [the] law and code by not providing the

services [they] were hired to provide as part of the special education”). In particular, the

plaintiffs allege that S.G. has not received any special education since “being placed in

1 Because subject matter jurisdiction is contested in this case, the court will consider not only the

allegations in the Complaint, but also materials outside the pleadings, including the parties’ affidavits. See Romano v. Kazacos, 609 F.3d 512, 520 (2d Cir. 2010).

3

home bound tutoring,” id.; that S.G. has been wrongfully separated from her high school

peers, id. at 6; and that, as a result, S.G. has experienced emotional distress, loss of

sleep, loss of productivity, pain and suffering, mental anguish, and feelings of distress,

anxiety, depression, and grief, id. at 17. The Complaint seeks money damages from

the defendants, alleging that they have violated a variety of state, federal, and

international laws, including the United Nations Declaration on the Rights of Indigenous

Peoples, id. at 12-13; the Thirteenth, Fourteenth, and Fifteenth Amendments of the

United States Constitution, id. at 6-7; and Connecticut laws on fraud, defamation,

malpractice, and intentional infliction of emotional distress. See id. at 8-10, 17-18.

III. STANDARD OF REVIEW

Under Federal Rule of Civil Procedure 12(b)(1), “[a] case is properly dismissed

for lack of subject matter jurisdiction . . . when the district court lacks the statutory or

constitutional power to adjudicate it.” Makarova v. United States, 201 F.3d 110, 113 (2d

Cir. 2000). The plaintiff bears the burden of proving the existence of subject matter

jurisdiction by a preponderance of the evidence. Id. In determining whether the plaintiff

has met this burden, “the court must take all facts alleged in the complaint as true and

draw all reasonable inferences in favor of [the] plaintiff.” Nat. Res. Def. Council v.

Johnson, 461 F.3d 164, 171 (2d Cir. 2006). In addition, a district court “may refer to

evidence outside the pleadings” when “resolving a motion to dismiss for lack of subject

matter jurisdiction under Rule 12(b)(1)[.]” Makarova, 201 F.3d at 113.

IV. DISCUSSION

The court will first address whether this case should be remanded to Connecticut

Superior Court. It will then address the defendants’ Motions to Dismiss and the

plaintiffs’ Motion for Summary Judgment.

4

A. Remand

During an in-person status conference held on January 29, 2019, this court

raised the concern that removal of the case may have been improper because Hamelett

had not signed Dolliver and Bender’s Notice of Removal or filed a written notice of

consent to removal. See Defs.’ Mem. on Removal at 1.

Section 1446 of title 28 of the United States Code outlines the procedures for

removing a civil action from state court to federal court. See Teamsters Local 404

Health Servs. & Ins. Plan v. King Pharm., Inc., 906 F.3d 260, 266 (2d Cir. 2018). In

2011, that statute was amended to require that “all defendants who have been properly

joined and served must join in or consent to the removal of the action.” 28 U.S. §

1446(b)(2)(A). This amendment codified the well-established rule that removal requires

the unanimous consent of all defendants, also known as the rule of unanimity. See

Ortiz v. City of New York, No. 13 CIV. 136 JMF, 2013 WL 2413724, at *1 (S.D.N.Y.

June 4, 2013).

The statute did not address what form a consent to removal must take, see 28

U.S.C. § 1446(b)(2)(A) (providing merely that all defendants “must join in or consent to

the removal of the action”), and the Second Circuit has not addressed the question, see

Pietrangelo v. Alvas Corp., 686 F.3d 62, 66 (2d Cir. 2012); (“Although we have not yet

advised what form a consent to removal must take, we agree with the district court that

the remaining defendants must independently express their consent to removal.”);

Abdullah v. Erdner Bros, Inc., No. 3:14-CV-01742-VAB, 2015 WL 1190141, at *4 (D.

Conn. Mar. 16, 2015) (“The Second Circuit has not yet advised what form a consent to

removal must take[.]”) (internal quotation marks omitted). However, district courts in this

Circuit have generally required each defendant to “either sign the notice of removal or 5

subsequently provide the Court with their unambiguous written consent to removal

within [ ] thirty days [of receiving service of the initial pleading].” Metro. Transp. Auth. v.

U.S. Fid. & Guar. Co., No. 14 CIV. 9059 PAE, 2015 WL 1730067, at *4 (S.D.N.Y. Apr.

14, 2015) (collecting cases). Most of these district courts have also held that “it is

insufficient for a defendant who has not signed the removal petition to merely advise the

removing defendant that it consents to removal and that the removing defendant may

represent such consent to the Court on its behalf.” Id.; see also Bedminster Fin. Grp.,

Ltd. v. Umami Sustainable Seafood, Inc., No. 12 CIV. 5557 JPO, 2013 WL 1234958, at

*6 (S.D.N.Y. Mar. 26, 2013) (collecting cases); but see Doe v. Zucker, No.

117CV1005GTSCFH, 2018 WL 3520422, at *5 (N.D.N.Y. July 20, 2018) (concluding on

the basis of caselaw from other circuits that the rule of unanimity was satisfied when the

notice of removal represented that a non-signing defendant had consented to the

removal).

The defendants in this case acknowledge that Hamelett “did not sign the notice

of removal or file a notice of consent to removal until January 30, 2019.” See Defs.’

Mem. on Removal at 3. Instead, Hamelett merely advised Dolliver and Bender of her

consent to removal, and those two defendants, in turn, represented such consent to the

court. See id. The defendants also recognize that this form of consent does not satisfy

the rule of unanimity as set forth by “the great weight of judicial authority from the

District Courts in this jurisdiction[.]” Id. at 6. Nevertheless, the defendants argue that,

because the Second Circuit has not specified the form of consent required by section

1446, this court should consider adopting a more flexible approach to the unanimity

requirement. See id. at 6-9. In particular, the defendants note that the Eighth Circuit,

6

among others, has held that this requirement is satisfied when one defendant

represents in his removal notice that his codefendants consent to the removal. 2 Id.

However, this court need not decide whether Hamelett’s representation of

consent satisfies the rule of unanimity because, even if her consent was defective, the

time period for remanding the case on the basis of such a defect has expired.

Specifically, section 1447(c) of title 28 of the United States Code provides:

A motion to remand the case on the basis of any defect other than lack of subject matter jurisdiction must be made within 30 days after the filing of the notice of removal under section 1446(a). If at any time before judgment it appears that the district court lacks subject matter jurisdiction, the case shall be remanded.

The Second Circuit has interpreted this provision as prohibiting district courts from

remanding a case more than 30 days after removal, except when the basis for remand

is lack of subject matter jurisdiction. See Mitskovski v. Buffalo & Fort Erie Pub. Bridge

Auth., 435 F.3d 127, 131 (2d Cir. 2006); see also Siverls-Dunham v. Seung Huen Lee,

No. 05 CIV. 7518 (PKC), 2006 WL 510504, at *3 (S.D.N.Y. Feb. 27, 2006). Moreover,

courts in this Circuit have held that failure to comply with the rule of unanimity is a

procedural, rather than a jurisdictional, defect. See, e.g., Bank of Am. Nat. Ass'n v.

Derisme, No. 3:10CV900 MRK, 2010 WL 3211066, at *9 (D. Conn. Aug. 13, 2010)

(“Although the Second Circuit has apparently not commented on this specific issue,

other Courts of Appeals and district courts in this Circuit have held that a violation of the

rule of unanimity is, like an untimely removal notice, a procedural defect which may be

2 The court notes that “the circuits have split on this issue.” Griffioen v. Cedar Rapids & Iowa City

Ry. Co., 785 F.3d 1182, 1186 (8th Cir. 2015). While “[t]he Fourth, Sixth, and Ninth Circuits have held that a statement in one defendant’s timely removal notice that its codefendants consent is sufficient[,] [t]he Seventh and Fifth Circuits . . . have suggested that in most situations a defendant may not give notice of consent on another defendant’s behalf.” Id. (internal citations omitted).

7

waived by the plaintiff.”) (collecting cases); Allstate Ins. Co. v. Zhigun, No. 03 CIV.

10302 (SHS), 2004 WL 187147, at *3 n.2 (S.D.N.Y. Jan. 30, 2004) (same); Flagler v.

Budget Rent A Car Sys., Inc., 538 F. Supp. 2d 557, 558 n.1 (E.D.N.Y. 2008) (same);

Johnson v. Adams, No. 914CV811GLSDEP, 2016 WL 1178754, at *2 (N.D.N.Y. Mar.

23, 2016) (same). Thus, because concerns about Hamelett’s consent were first raised

on January 29, 2019, well after the 30-day period for objecting to procedural defects

had expired, this court has no authority to remand the case to state court for failure to

comply with the rule of unanimity. Accordingly, the plaintiffs’ Motion to Deny Notice of

Removal on Jurisdiction (Doc. No. 38), construed as a motion to remand, is denied.

B. Motion to Dismiss

The defendants argue that any claims brought by S.G. must be dismissed

because, inter alia, S.G. is a minor who lacks capacity to sue on her own behalf. See

Memorandum of Law in Support of Motion to Dismiss Adversary Proceeding

(“Hamelett’s Mem.”) (Doc. No. 21-1) at 4-5; Dolliver & Bender’s Mem. at 1 n.1. As to

Gibson, the defendants argue, inter alia, that this court lacks subject matter jurisdiction

over any claims brought by him because he failed to exhaust his administrative

remedies under the Individuals with Disabilities in Education Act (“IDEA”), 20 U.S.C. §

1401, et seq. See Dolliver & Bender’s Mem. at 10-16. The court will address these

arguments in turn.

1. S.G.

Pursuant to Federal Rule of Civil Procedure 17(b), only individuals with capacity

to sue in state court may sue on their own behalf in federal court. See also Mulready v.

Mulready, No. CIV 306CV00934 AWT, 2007 WL 1791120, at *1 (D. Conn. June 16,

2007). In Connecticut, “[i]t is well established that a child may bring a civil action only

8

by a guardian or next friend, whose responsibility it is to ensure that the interests of the

ward are well represented.” Orsi v. Senatore, 230 Conn. 459, 466–67 (1994) (internal

quotation marks omitted, emphasis added). Connecticut law defines a “minor” as a

person under 18 years of age. Conn. Gen. Stat. § 1-1d.

The record in this case shows that S.G. is 14 years old, and therefore a minor

under Connecticut law. See Bender’s Decl. at ¶ 3 (testifying that S.G. was 5 years old

in 2010). The plaintiffs do not dispute this fact. Thus, because S.G. does not have

capacity to sue in federal court, she is dismissed as a plaintiff in this action.

Furthermore, to the extent that the Complaint seeks to have Gibson bring claims

on behalf of S.G., his daughter, those claims must be dismissed because Gibson is a

pro se litigant. In the Second Circuit, it is well established that a non-attorney parent

may not bring an action on behalf of his child without representation by counsel. See

Berrios v. New York City Hous. Auth., 564 F.3d 130, 133 (2d Cir. 2009); Armatas v.

Maroulleti, 484 F. App'x 576, 577–78 (2d Cir. 2012). Thus, because the records of this

court do not show that Gibson is a member of the bar, and because Gibson does not

claim otherwise, the court dismisses all causes of action that Gibson seeks to assert on

behalf of S.G. or that S.G., a minor, seeks to assert on her own behalf.

2. Gibson

The defendants argue, inter alia, that this court lacks subject matter jurisdiction

over any claims that Gibson seeks to bring on his own behalf because Gibson failed to

exhaust the administrative remedies under the IDEA. See Dolliver & Bender’s Mem. at

11-16.

The IDEA is “a Spending Clause statute that seeks to ensure that all children

with disabilities have available to them a free appropriate public education.” Schaffer ex 9

rel. Schaffer v. Weast, 546 U.S. 49, 51 (2005) (internal quotation marks omitted). Under

this statutory scheme, “school districts must create an ‘individualized education

program’ (IEP) for each disabled child.” Id. (internal quotation marks omitted).

Specifically, “[s]tate educational authorities must identify and evaluate disabled children,

§§ 1414(a)-(c), develop an IEP for each one, § 1414(d)(2), and review every IEP at

least once a year, § 1414(d)(4)” Id. at 53. “Each IEP must include an assessment of

the child's current educational performance, must articulate measurable educational

goals, and must specify the nature of the special services that the school will provide.”

Id.

The IDEA also provides “a variety of procedural safeguards with respect to the

provision of free appropriate public education by school districts.” Lillbask ex rel.

Mauclaire v. State of Conn. Dep't of Educ., 397 F.3d 77, 81–82 (2d Cir. 2005) (internal

quotation marks omitted). Most relevant to this case, “[p]arents are [ ] entitled to

request a due process hearing in order to present complaints as to any matter relating

to the identification, evaluation, or educational placement of the child, or the provision of

a free appropriate public education.” Cave v. E. Meadow Union Free Sch. Dist., 514

F.3d 240, 245 (2d Cir. 2008) (internal quotation marks omitted). In response to such a

complaint, “a state or local hearing officer must conduct an impartial due process

hearing and render a decision.” Lillbask, 397 F.3d at 82. If a parent or guardian is

dissatisfied with that decision, he or she “may appeal to the State educational agency,

which in turn must conduct an impartial review.” Lillbask, 397 F.3d at 82 (internal

quotation marks omitted).

10

Failure to exhaust the IDEA’s administrative remedies deprives the court of

subject matter jurisdiction over suits filed under the IDEA. Cave v. E. Meadow Union

Free Sch. Dist., 514 F.3d 240, 245 (2d Cir. 2008). Furthermore, even if a plaintiff does

not plead an IDEA violation, the IDEA exhaustion requirement will apply when the

plaintiff “assert[s] claims for relief available under the IDEA, regardless of the statutory

basis of [his] complaint[.]” L.K. v. Sewanhaka Cent. High Sch. Dist., 641 F. App'x 56, 57

(2d Cir. 2016) (quoting Cave, 514 F.3d at 245-46). As the Second Circuit has

explained, “[t]he purpose of the exhaustion rule is 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.” Cave, 514 F.3d

at 245-46. As a result, plaintiffs cannot sidestep the IDEA’s exhaustion requirement by

“cloak[ing] [their claims] in legal theories distinct from IDEA[.]” DiStiso v. Town of

Wolcott, 2006 WL 3355174 at *5 (D. Conn. Nov. 17, 2006).

Nor can they avoid the IDEA’s administrative procedures by bringing claims for

damages, even though such relief is not available under the IDEA itself. See Polera v.

Bd. of Educ. of Newburgh Enlarged City Sch. Dist., 288 F.3d 478, 486, 487-88 (2d Cir.

2002). The Second Circuit has held that “‘[r]elief available [under the IDEA] means

relief for the events, condition, or consequences of which the person complains, even if

not necessarily relief of the kind the person prefers.” Taylor v. Vermont Dep't of Educ.,

313 F.3d 768, 790 (2d Cir. 2002) (internal quotation marks and alterations omitted).

Thus, “if the ‘theory’ behind a claim relates to the ‘education of disabled children,’ IDEA

exhaustion is required,” even if the claim is pled under a different statute and even if it

seeks relief that is not available under the IDEA. L.K., 641 F. App'x at 57; see also

11

Stropkay v. Garden City Union Free Sch. Dist., 593 F. App'x 37, 40 (2d Cir. 2014)

(“Where, as here, plaintiffs raise grievances related to the education of disabled

children, they are obligated to exhaust their administrative remedies before filing suit in

federal court[.]”) (internal quotation marks omitted).

While the IDEA’s exhaustion requirement is broad in scope, it is “not an inflexible

rule.” Murphy v. Arlington Cent. Sch. Dist. Bd. of Educ., 297 F.3d 195, 199 (2d Cir.

2002). The Second Circuit has identified three situations where exhaustion should be

excused, namely, where “(1) it would be futile to resort to the IDEA's due process

procedures; (2) an agency has adopted a policy or pursued a practice of general

applicability that is contrary to the law; or (3) it is improbable that adequate relief can be

obtained by pursuing administrative remedies.” Id. “The burden of proving the

applicability of one of these exceptions falls on the party seeking to avoid exhaustion.”

Id.

In this case, although Gibson does not plead a violation of the IDEA, all of his

claims rest on the core allegation that S.G. was provided inadequate special education

services. 3 See id. In particular, Gibson seeks to challenge the defendants’ decisions

concerning the educational placement of S.G. in homebound instruction and the quality

of education services provided to her through that instruction. See id. The IDEA,

however, affords a remedy for precisely these types of grievances. See 20 U.S.C. §

3 The court notes that, although Gibson cannot assert claims on behalf of S.G. because he is not

an attorney, see, supra, at 9, Gibson can prosecute IDEA claims on his own behalf. Winkelman ex rel. Winkelman v. Parma City Sch. Dist., 550 U.S. 516, 535 (2007). The Supreme Court has explained that the IDEA “creates in parents an independent stake not only in the procedures and costs implicated by this process but also in the substantive decisions to be made.” Id. at 531. As a result, parents have standing to pursue IDEA claims on their own behalf. E.M. v. New York City Dep't of Educ., 758 F.3d 442, 451 (2d Cir. 2014).

12

1415(b)(6)(A) (allowing aggrieved parties to challenge any decision “relating to the

identification, evaluation, or educational placement of the child, or the provision of a free

appropriate public education to such child.”). As a result, the IDEA’s exhaustion

requirement applies to all of the claims raised in the Complaint. 4

Moreover, Gibson does not dispute that he did not request a due process

hearing, file a complaint with the relevant state or local agency, or otherwise seek

recourse from the administrative procedures established by the IDEA. Nor does Gibson

argue that he should be excused from exhausting administrative remedies. See

Murphy, 297 F.3d at 199 (identifying exceptions to the IDEA’s exhaustion requirement).

Indeed, none of Gibson’s submissions acknowledge, much less respond to, the

defendants’ arguments concerning exhaustion under the IDEA. As a result, Gibson has

not carried his burden of showing that this court has subject matter jurisdiction over his

causes of action. The Complaint is therefore dismissed in its entirely for lack of subject

matter jurisdiction.

V. CONCLUSION

For the foregoing reasons, the plaintiffs’ Motion to Deny Notice of Removal on

Jurisdiction (treated by the court as a motion to remand) (Doc. No. 38) is denied, and

the defendants’ Motions to Dismiss (Doc. Nos. 21, 26) are granted. As a result, the

plaintiffs’ Motion for Summary Judgment (Doc. No. 29) is denied as moot.

4 Indeed, even the plaintiffs’ allegations that the defendants committed “acts of slavery” arise out

of the defendants’ decisions regarding the identification, evaluation, and educational placement of S.O. See Compl. at 6 (asserting that the defendants have committed “acts of slavery” by placing S.O. “on a college campus away from her peers which [sic] are high school students” and by not providing her with “course work or studies from [sic] her level of schooling”). Thus, in addition to being frivolous and entirely unsupported by factual allegations, the plaintiffs’ Thirteenth Amendment claim is dismissed for failure to exhaust the IDEA’s administrative remedies.

13

The Complaint is dismissed without prejudice. Gibson may file an Amended

Complaint within thirty days of the date of this Ruling if he can show that he either (1)

properly exhausted the administrative remedies under the IDEA, or (2) qualifies for one

of the exceptions to the IDEA exhaustion requirement.

If Gibson wishes to pursue claims on behalf of S.G., he must retain counsel and

said counsel must file an appearance in this case within thirty days of the date of this

Ruling. If Gibson is unable to retain counsel, he may file a motion for appointment of

counsel within thirty days of the date of this Ruling. However, the court reminds Gibson

that such a motion will only be granted if this court determines that “the appointment will

serve the interests of justice based upon factors such as (a) a party’s apparent ability or

inability to afford legal counsel, (b) the likelihood that counsel may be secured under

alternative fee arrangements, and (c) the apparent merit of the party’s claims or

defenses.” D. Conn. L. R. 83.10(c)(1).

SO ORDERED.

Dated at New Haven, Connecticut this 1st day of April, 2019.

/s/ Janet C. Hall__________ Janet C. Hall United States District Judge

14

D. Conn.: Gibson et al. v. Doliver... | Special Education Law