Skip to main content
Special Education Law
Sign In

A.M. et al. v. the City of New York et al.

July 11, 2023

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -------------------------------------------------------------- x A.M., individually and as mother and natural : guardian of R.S. and R.S., individually, :

Plaintiffs, : MEMORANDUM & ORDER

-against- : 21-CV-5191 (ENV)(CLP)

THE CITY OF NEW YORK and THE NEW : YORK CITY DEPARTMENT OF EDUCATION, :

Defendants. :

x VITALIANO, D.J.

On September 17, 2021, plaintiff A.M., individually and as mother and guardian of R.S.,

and R.S., individually, commenced this action seeking attorneys’ fees and costs after an award in

an action filed under the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et. seq.

(“IDEA”). Compl., ECF Dkt. 1. On January 7, 2022, plaintiffs filed a letter motion for

settlement approval. ECF Dkt. 12. Thereafter, the litigation moved through the clerk’s office

like a wrecking ball, with letters of counsel regarding the subject matter of the initial motion

being characterized as independent individual letter motions.

As a result of these filings, two separate reports and recommendations (“R&Rs”) were

generated by Magistrate Judge Cheryl L. Pollak. In an attempt to rationalize the filings, this

Court will treat the First R&R, ECF Dkt. 16, as recommending denial of plaintiffs’ motion to

approve settlement of the attorneys’ fees dispute and the Second R&R, ECF Dkt. 22, as

reaffirming the first.1

1 The motion that resulted in the Second R&R denying settlement approval purportedly sought reconsideration by this Court of Judge Pollak’s First R&R, but, at the time that motion was

1

For the reasons that follow, both R&Rs are adopted in full and plaintiffs’ third letter

motion for settlement approval is denied without prejudice with leave for the parties to submit

properly styled and supported motions for that relief. All other letters or writings on the docket

designated as motions are terminated.

Background

On September 17, 2021, following the finding by an Impartial Hearing Officer that infant

R.S. had not been provided with a Free Appropriate Public Education as required by IDEA,

plaintiffs filed the instant lawsuit seeking attorneys’ fees for the underlying action. Compl. at 2.

Plaintiffs represent that, as they are prevailing parties in the underlying due process proceedings,

they are entitled to an award of legal fees. Id. at 2–3. They further represent that they exhausted

all necessary administrative remedies. Id. at 3.

On January 7, 2022, plaintiffs notified Judge Pollak of an agreement to settle and

requested leave to file a stipulation of settlement and dismissal. ECF Dkt. 12. Plaintiffs

described work done by counsel on their behalf and asserted that, as R.S. would not be involved

in any monetary recovery for the action, judicial approval did not require an infant compromise

order under Local Civil Rule 83.2(a)(1). Id. Concerned that plaintiffs provided insufficient

further information from plaintiffs, including “the amount [to] be paid, the fee rate to be charged,

[and] contemporaneous billing records . . . .” Electronic Order dated Jan. 10, 2022 (citing New

York State Ass’n for Retarded Child., Inc. v. Carey, 711 F.2d 1136, 1139 (2d Cir. 1983)).

Plaintiffs’ counsel subsequently filed a second letter motion which added an hourly

made, the Court had not disposed of the First R&R, and so there was no order of the district court to reconsider. Accordingly, this memorandum and order on the First R&R will apply with equal force and effect to the second, which is deemed merged with the first.

2

billing rate, the number of hours worked, and a justification for the billing rate based on her

years of experience, but she omitted contemporaneous billing records. ECF Dkt. 13. After yet

another request from Judge Pollak, Electronic Order dated Jan. 12, 2022, plaintiffs’ counsel

finally submitted a third letter motion for settlement approval that included contemporaneous

billing records, ECF Dkt. 15, as well as a joint proposed settlement amount. ECF Dkt. 14.

In response to this third letter motion, Judge Pollak issued, sua sponte, the First R&R,

recommending denial of plaintiffs’ motion without prejudice. Though Judge Pollak agreed that

an infant compromise hearing was unnecessary, First R&R at 4, she pointed out two

shortcomings in plaintiffs’ requests. First, Local Rule 7.1(a) requires parties seeking dispositive

relief to file a notice of motion, memorandum of law, and supporting affidavits and exhibits

where necessary. Id. at 5–6. Judge Pollak went on to hold that, as a dispositive motion,

plaintiffs’ settlement approval motion must be filed in compliance with that rule.2 Id. at 5. She

also reminded the parties that Local Rule 83.2(a)(2) required that she review the requested

attorneys’ fees and costs for reasonableness and that supporting proof be submitted with the

request. Id. at 6–7. Given plaintiffs’ failure to comply with these rules, the R&R recommended

that the application be denied without prejudice. Id. at 7.

On February 15, 2022, plaintiffs submitted timely written objections to the First R&R.

Obj., ECF Dkt. 17. Plaintiffs contended that, because no claims are asserted on behalf of R.S.,

“no inquiry as to the fairness of the settlement to R.S.” was necessary, id. at 4, but they failed to

address Judge Pollak’s findings regarding Local Civil Rule 7.1(a)’s motion practice

2 Judge Pollak also noted that, without affidavits, the court had no evidence that defendants agreed with the proposed settlement. First R&R at 6. The parties then filed a joint stipulation of settlement, ECF Dkt. 18, and a letter by defendants, ECF Dkt. 19, clarifying defendants’ agreement.

3

requirements. Alongside their objections, plaintiffs submitted, under seal, a release form signed

by A.M. on behalf of both herself and R.S., as well as the proposed settlement agreement. ECF

Dkt. 18.

On March 2, 2022, defendant New York City Department of Education (“DOE”) chimed

in for the first time, confirming agreement of settlement, agreeing that an infant compromise

order was not necessary, and asserting that IDEA “fees-only” settlements are frequently filed and

approved as notices of settlement, rather than motions pursuant to Local Civil Rule 83.2(a)(1).

Dkt 19. DOE did not, however, provide any support for this last assertion. Id.

Further burdening the record, plaintiffs filed, on June 10, 2022, a letter motion to vacate

the First R&R. ECF Dkt. 21. The letter motion spotlighted the reasons why plaintiffs believed

an infant compromise hearing was not required, an issue that had already become a red herring

since no one, including Judge Pollak in her R&R, had taken the position that such a hearing was

required. Id. In any event, plaintiffs noted that, in the interim, R.S. had reached his majority,

and submitted with the motion was a release form that he himself had signed. ECF Dkt. 20.

All of this prompted Judge Pollak to issue her Second R&R on August 8, 2022,

recommending that plaintiffs’ second letter motion be denied. ECF Dkt. 22. The R&R ticked

off all the failings of the settlement approval request, including the failure to comply with the

Court’s Local Rules governing dispositive motions and the failure to provide record information

critical to a determination of the motion’s reasonableness. Id. at 5–10. She also reminded the

parties that the award of attorneys’ fees in IDEA lawsuits is discretionary and must be found

reasonable. Id. at 7–8. No written timely objection to this R&R was filed by any party, and it

will be reviewed coterminously with objections to the First R&R and resolved on the same basis.

4

Standard of Review

In reviewing a report and recommendation of a magistrate judge, a district judge “may

accept, reject, or modify, in whole or in part, the findings or recommendations made by the

magistrate judge.” 28 U.S.C. § 636(b)(1)(C). Further, a district judge is required to “determine

de novo any part of the magistrate judge’s disposition that has been properly objected to.” Fed.

R. Civ. P. 72(b)(3); see also 28 U.S.C. § 636(b)(1); Arista Records, LLC v. Doe 3, 604 F.3d 110,

116 (2d Cir. 2010). Importantly, “objections must be specific and clearly aimed at particular

findings in the magistrate judge’s proposal.” New York City Dist. Council of Carpenters v. Allied

Design & Constr., LLC, 335 F. Supp. 3d 349, 351 (E.D.N.Y. 2018); see also Barratt v. Joie, No.

90 Civ. 0324 (LTS) (THK), 2002 WL 335014, at *1 (S.D.N.Y. Mar. 4, 2002).

“To accept those portions of the report to which no timely objection has been made, a

district court need only satisfy itself that there is no clear error on the face of the record.” Ruiz v.

Citibank, N.A., No. 10 Civ. 5950 (KPF) (RLE), 2014 WL 4635575, at *2 (S.D.N.Y. Aug. 19,

2014) (quoting King v. Greiner, No. 02 Civ. 5810 (DLC), 2009 WL 2001439, at *4 (S.D.N.Y.

July 8, 2009)). Clear error exists “where, upon a review of the entire record, [the district judge]

is left with the definite and firm conviction that a mistake has been committed.” Saveria JFK,

Inc. v. Flughafen Wien, AG, No. 15-CV-6195 (RRM) (RLM), 2017 WL 1194656, at *2

(E.D.N.Y. Mar. 30, 2017).

Furthermore, objections that are general or conclusory or that “merely recite the same

arguments presented to the magistrate judge” do not constitute proper written objections and are

also reviewed only for clear error. Sanders v. City of New York, No. 12-CV-0113 (PKC) (LB),

2015 WL 1469506, at *1 (E.D.N.Y. Mar. 30, 2015) (citation omitted).

5

Discussion

At the end of the day, despite all of the fume and fury, there is not much to decide. Judge

Pollak has repeatedly, and correctly, asserted that Local Civil Rule 83.2(a)(2) compels judicial

inquiry into the reasonableness of attorneys’ fees in this matter. First R&R at 4, 6–7; Second

R&R at 5–7.3 She has also ruled that Local Civil Rule 7.1(a), section 1415(i)(3)(b) of IDEA, and

this Court’s Individual Rule I.I each compel substantially the same requirement. Second R&R at

7. Notwithstanding, plaintiffs have stonewalled Judge Pollak’s clear mandate that they comply

with these rules.

Stonewall or not, plaintiffs are, of course, entitled to file a proper objection to an R&R

they believe aggrieves them. In response to the First R&R, plaintiffs made the timely, albeit

brief, objection that, under Local Civil Rule 83.2, “no inquiry as to the fairness of the settlement

to R.S.” and “no infant’s compromise order” should be required. Obj. at 4. The latter

contention—which tracks to Local Civil Rule 83.2(a)(1)—is moot, as the parties and Judge

Pollak agree on this point. See, e.g., First R&R at 4; Second R&R at 6. The former, rather

cursory contention—which tracks to Local Civil Rule 83.2(a)(2)—warrants de novo review, and,

upon such review, the objection is overruled.

Perhaps still ensnarled in the now-academic dispute about the necessity of an infant

compromise hearing, plaintiffs cite to School for Language & Communication Development v.

N.Y. State Department of Education., No. 02-CV-0269 (JS) (JO), 2010 WL 1740416, at *2

(E.D.N.Y. Apr. 7, 2010), report and recommendation adopted, 2010 WL 1752183 (E.D.N.Y.

Apr. 28, 2010), to support their proposition that this scrutiny of a judicial hearing is not required

3 Stray references to 83.2(b) in each Report and Recommendation, that proceed to instead quote from 83.2(a)(2), appear to be typographical errors.

6

to gain approval of their settlement agreement and fee application. Not only is this case silent on

that proposition, but if it speaks at all, it speaks against it. Id. at *4. Indeed, School for

Language was able to proceed with settlement approval in large part because the plaintiffs’

“extensive submissions” enabled the magistrate to review the settlement for fairness. Id. at *2–4.

Here, by contrast, plaintiffs have been slow to respond to basic requests from Judge Pollak, such

as for contemporaneous billing records and the amount of settlement (requested after the first

letter motion, Electronic Order dated Jan. 10, 2022, but submitted only with the third letter

motion, ECF Dkt. 14, 15) and typical attorneys’ fees in similar actions (requested in the First

R&R and still not submitted). At bottom, the process Judge Pollak has requested and seeks to

enforce in her R&R is fully supported by past and solid practice. Plaintiffs have offered nothing

in support of their objection that suggests otherwise.

Lastly, defendant DOE’s filing, ECF Dkt. 19, is untimely and therefore not a proper

written objection. To the extent that this objection captures a portion of the First R&R not

already reviewed de novo on the objection filed by plaintiffs, DOE’s objection is subject to clear

error review. On that basis, the objection is overruled. The R&R is clear and correct in its

reasoning and its holding.

7

Conclusion

For the foregoing reasons, both the First R&R and the Second R&R are adopted in full by

the Court. Plaintiffs’ motion to vacate is denied, and the parties’ third motion for settlement

approval is denied without prejudice. The parties may re-file their proposal for settlement in

accordance with the requirements set forth by Judge Pollak in the two R&Rs filed by her on the

docket.

So Ordered.

Dated: Brooklyn, New York June 30, 2023

/s/ Eric N. Vitaliano ERIC N. VITALIANO United States District Judge

8

E.D.N.Y.: A.M. et al. v. the City... | Special Education Law