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Rekowicz v. Sachem School District

September 17, 2012·Sachem

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK --------------------------------x ELIZABETH REKOWICZ on behalf of her son, STEVEN CONGEMI,

Plaintiff, MEMORANDUM & ORDER 11-CV-1561(JS)(ETB) -against-

SACHEM CENTRAL SCHOOL DISTRICT,

Defendant. ---------------------------------x APPEARANCES For Plaintiff: Scott M. Mishkin, Esq. One Suffolk Square, Suite 240 Islandia, NY 11749.

For Defendant: Joseph E. Madsen, Esq. Susan E. Fine, Esq. Ingerman Smith, L.L.P. 150 Motor Parkway, Suite 400 Hauppauge, NY 11788

SEYBERT, District Judge:

Pending before the Court are Plaintiff Elizabeth

Rekowicz’s Objections to Magistrate Judge E. Thomas Boyle’s

Report and Recommendation (“R&R”) recommending that the Court

grant in part and deny in part Plaintiff’s motion to amend her

Complaint. Defendant Sachem Central School District opposes

Plaintiff’s motion to amend. For the following reasons, Judge

Boyle’s R&R is ADOPTED IN PART in accordance with the following

discussion.

BACKGROUND

The R&R provides a discussion of the allegations in

Plaintiff’s Proposed Amended Complaint (the “PAC”). Briefly,

Plaintiff proposes to add (1) Plaintiff’s son, Steven Congemi,

as a plaintiff in the case; (2) claims under the IDEA, the ADA,

the Rehabilitation Act, and Section 1983 against eleven

individual defendants in their official and individual

capacities (see R&R 5), and (3) a Section 1983 claim against the

District. In addition to addressing these proposed additions,

Judge Boyle considered the futility vel non of Plaintiff’s IDEA,

ADA, and Rehabilitation Act claims against the District. Judge

Boyle concluded that all but two of Plaintiff’s proposed

amendments would be futile and he recommended that the motion to

amend be denied except insofar as Plaintiff seeks to add (1) her

son as a named plaintiff and (2) a Section 1983 claim against

James Nolan. (R&R 18.)

DISCUSSION

Plaintiff challenges the R&R on the following grounds:

she argues that (1) she pled the personal involvement of the

individual defendants with sufficient plausibility to state

Section 1983 claims against them (Pl. Br. 4); (2) Judge Boyle

erred in rejecting her Section 1983 claim against the District

(id. at 8-9); (3) her official-capacity claims against the

proposed individual defendants were improperly rejected (id. at

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10-11); and (4) she sufficiently stated ADA and Rehabilitation

Act claims against all proposed defendants. She also (5)

clarifies that is seeking damages for IDEA violations under

Section 1983, not the IDEA itself.

A magistrate judge’s recommendations on nondispositive

issues may be set aside only to the extent that they are

“clearly erroneous” or “contrary to law.” Fed. R. Civ. P.

72(a).1

I. Personal Involvement

The Court agrees with Judge Boyle that, except for

proposed defendant James Nolan, Plaintiff has not provided

anything beyond conclusory allegations of the individuals’

personal involvement in any Section 1983 violations. (See R&R

8-10.) In her Objections, Plaintiff simply cites to the

paragraphs in the PAC that Judge Boyle already concluded were

insufficiently detailed without offering any argument (beyond

restating the Iqbal/Twombly pleading standard) why Judge Boyle

reached the wrong conclusion. (Pl. Br. 5-7.)

As to James Nolan, it appears that Plaintiff’s Section

1983 claim is predicated on his decision to truncate Plaintiff’s

son’s daily school schedule. This allegation goes to whether

school officials deprived Plaintiff’s son of a free appropriate

1 The Second Circuit has suggested that motions to amend are nondispositive. See Fielding v. Tollaksen, 510 F.3d 175, 178 (2d Cir. 2007).

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public education (“FAPE”)--i.e., whether the District violated

the IDEA. Because plaintiffs cannot use Section 1983 to obtain

damages for IDEA violations absent allegations that they were

denied IDEA’s “procedural safeguards or administrative

remedies,” Streck v. Bd. of Educ. of E. Greenbush Sch. Dist.,

280 F. App’x 66, 68 (2d Cir. 2008); Schafer v. Hicksville Union

Free Sch. Dist., No. 06–CV–2531, 2011 WL 1322903, at *18

(E.D.N.Y. Mar. 31, 2011); French v. N.Y.S. Dep’t of Educ.

[“French I”], No. 04-CV-0434, 2010 WL 3909163, at *11 (N.D.N.Y.

Sept. 30, 2010) aff’d, --- F. App’x ----, 2011 WL 5222856 (2d

Cir. Nov 3, 2011) [“French II”], Plaintiff’s Section 1983 claim

against Nolan is futile.

Accordingly, the Court adopts in part the R&R as it

relates to Plaintiff’s proposed Section 1983 claims against the

proposed individual defendants. The Court agrees that Plaintiff

has not stated Section 1983 claims against ten of the eleven

individuals, and it further concludes that she has not stated a

Section 1983 claim against Nolan either.

II. Municipal Liability

Judge Boyle also rejected Plaintiff’s attempt to add a

Section 1983 claim against the District, finding that Plaintiff

had not adequately alleged an unlawful custom or policy. (R&R

11.) In doing so, Judge Boyle recognized that (a) Nolan,

Plaintiff’s son’s principal, is alleged to have authorized

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Plaintiff’s son’s truncated schedule and (b) school principals

have been considered policymakers for the purposes of

establishing municipal liability under Section 1983. (R&R 12-13

& 12 n.11.) He reasoned, however, that allegations of a single,

isolated decision from a policymaker are insufficient to state a

claim against the District. (Id. at 13.) This rationale

conflates the ways that a plaintiff can establish liability

under Monell v. Department of Social Services, 436 U.S. 658, 98

S. Ct. 2018, 56 L. Ed. 2d 611 (1978); a single decision from

someone with policymaking authority can be enough to state a

Monell claim.2 See generally, e.g., Jones v. Town of E. Haven, -

-- F.3d ----, 2012 WL 3104523, at *6 (2d Cir. Aug. 1, 2012).

In any event, however, Plaintiff’s proposed Section

1983 claim against the District fails for reasons already

discussed in Section I. The decision to truncate Plaintiff’s

son’s school day goes to merits of whether Plaintiff’s son

received a FAPE and not whether there were defects in the

procedural or administrative remedies under IDEA. French I,

2010 WL 3909163, at *11.

III. Claims against Individuals in their Official Capacities

Plaintiff argues that, because she has plausibly

alleged a Section 1983 claim against the District, her claims

2 The Court agrees with Judge Boyle that Plaintiff has not plausibly alleged an unlawful custom, pattern, or practice. (See R&R 11-12.)

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against the individual defendants in their official capacities

should not have been rejected as futile. (Pl. Br. 10.) Having

concluded above that Plaintiff has not, in fact, stated a

Section 1983 claim against the District, the Court agrees with

Judge Boyle that Plaintiff’s proposed claims against the

individual defendants in their official capacities are futile.

IV. Plaintiff’s ADA and Rehabilitation Act Claims

Judge Boyle also recommended that Plaintiff’s proposed

ADA and Rehabilitation Act claims be rejected as futile. As far

as the claims against the proposed individual defendants,

Plaintiff has not offered any authority or persuasive argument

that Judge Boyle’s recommendation was incorrect.

As to the claims against the District, Judge Boyle

found that Plaintiff’s allegations were futile because they did

not allege anything more than an IDEA violation and, without

more, IDEA violations cannot form the basis for ADA or

Rehabilitation Act claims. (R&R 17.) Rather, a plaintiff needs

to show that a defendant acted with bad faith or gross

misjudgment. See French II, 2011 WL 5222856, at *4. The Court

concludes that Plaintiff, in asserting that District employees

manipulated her son’s test scores to accelerate his progress

(PAC ¶ 135), has alleged that the District acted with bad faith

sufficient to support a claim under the ADA or the

Rehabilitation Act. See French II, 2011 WL 5222856, at *4

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(listing elements). Accordingly, Plaintiff will be permitted to

proceed with claims that the District violated the ADA and the

Rehabilitation Act.3

V. Plaintiff’s IDEA Claims

Judge Boyle noted that because damages are not

available under the IDEA, Plaintiff’s proposed IDEA claims

against the proposed individual defendants were futile. (R&R

18.) He noted, however, that Plaintiff may be entitled to seek

damages for IDEA violations under Section 1983 (id.), and

Plaintiff clarified that this is her intent (Pl. Br. 13). For

reasons already discussed, Plaintiff may seek damages under

Section 1983 for IDEA violations only under limited

circumstances which are not alleged to be present here.

[Remainder of Page Intentionally Blank]

3 It is not wholly clear whether the District understood Plaintiff’s motion to amend as seeking to add ADA and Rehabilitation Act claims against the District (see Docket Entry 29 at 4 n.2), perhaps because Plaintiff’s pro se Complaint, liberally construed, arguably asserted these claims already. In any event, the Court’s decision today is without prejudice to the District’s ability to move to dismiss any Amended Complaint.

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CONCLUSION

For the foregoing reasons, the Court adopts the R&R in

part. Plaintiff may amend her Complaint to add her son as a

plaintiff. She may also include IDEA, ADA, and Rehabilitation

Act claims against the District. Her remaining proposed

amendments are denied as futile. Plaintiff’s request for leave

to file a further amended complaint to address the significant

deficiencies that Judge Boyle identified in her PAC is denied.

She may move for leave to amend her complaint in the normal

course.

Separately, the Court notes that earlier in this case,

Judge Boyle received a stack of documents from Plaintiff while

she was proceeding pro se. There is no indication that these

materials were ever served on Defendant, and the Court has not

considered them. The Court will forward these documents to

Plaintiff’s counsel.

SO ORDERED.

/s/ JOANNA SEYBERT______ Joanna Seybert, U.S.D.J.

Dated: September 17, 2012 Central Islip, New York

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E.D.N.Y.: Rekowicz v. Sachem School... | Special Education Law