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Killoran v. Westhampton Beach School District et al.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK ----------------------------------x CHRISTIAN KILLORAN, on behalf of his son, AIDEN KILLORAN,

Plaintiff, MEMORANDUM & ORDER 20-CV-4121(JS)(SIL) -against-

WESTHAMPTON BEACH SCHOOL DISTRICT; MICHAEL RADDAY, as Superintendent; MARY ANNE AMBROSINI, as Director of Pupil Personnel; SUZANNE MENSCH, HALSEY C. STEVENS, JOYCE DONNESSON, and GEORGE R. KAST, as Board of Education Members,

Defendants. ----------------------------------x For Plaintiff: Christian Killoran, Esq., Pro Se 132-13 Main Street Westhampton Beach, New York 11978

For Defendants: Anne C. Leahey, Esq. Anne Leahey Law, LLC 17 Dumplin Hill Lane Huntington, New York 11743

SEYBERT, District Judge:

Pro se plaintiff Christian Killoran (“Plaintiff”),

individually and as parent to A.K., a child with Down Syndrome,

commenced this action against defendants Westhampton Beach School

District (“Westhampton” or the “District”), Michael Radday (“the

Superintendent”), Mary Anne Ambrosini (“Director of Pupil

Personnel”), Suzanne M. Mensch, Halsey C. Stevens, Joyce L.

1

Donnesson, and George R. Kast, Jr. (together, the “School Board,”

and collectively with Westhampton, the Superintendent, and the

Director of Pupil Personnel, the “Defendants”). Plaintiff’s

Complaint purports to allege violations of the “stay-put”

provision of the Individuals with Disabilities Education Act

(“IDEA”), 20 U.S.C. § 1415(j), the Americans with Disabilities Act

(“ADA”), 42 U.S.C. § 12101 et seq., Section 504 of the

Rehabilitation Act (“Section 504”), 29 U.S.C. § 701 et seq., and

42 U.S.C. § 1983 (“Section 1983”). (See Combined Verified

Complaint and Affidavit in Support of Order to Show Cause,

(“Compl.”), ECF No. 1.) 1

Currently pending before the Court is Defendants’ motion

to dismiss the Complaint in in its entirety (hereafter, “Dismissal

Motion”) (ECF No. 16.), and Plaintiff’s cross-motion for partial

summary judgment with respect to his IDEA claim (hereafter, the

“Cross Motion”). (ECF No. 19. 2) After careful consideration, for

the reasons stated herein, Defendants’ Dismissal Motion is

GRANTED, and Plaintiff’s Cross-Motion is DENIED.

1 Note that the Court cites to electronic case filing (“ECF”) system pagination throughout this Memorandum and Order. 2 In his Cross-Motion (ECF No. 19), Plaintiff also includes his opposition to Defendants’ Dismissal Motion. (See infra, Background, Part II.) To the extent the Court cites to this document in the context of Plaintiff’s opposition, it will use the notation “Pl. Opp’n”. 2

BACKGROUND

I. Factual Background

The parties and the Court are familiar with the extensive

facts underlying the present litigation. In the interest of

brevity, only the proceedings relevant to the issues presented in

the parties’ motions are discussed below. 3

On September 20, 2019, in response to a prior order from

this Court in a related case (see Case No. 19-CV-5078, Sept. 6,

2019 Elec. Order), the parties reached an agreement concerning

A.K.’s pendency placement during the parties’ ongoing

administrative proceedings (hereafter, the “2019 Agreement”).

(See 2019 Agreement, ECF No. 1 at 9-11. 4) Pursuant to said

Agreement, A.K. would receive a hybrid of services. (Id. at ¶¶ 1-

3.) For example: A.K. would first be bussed to the District where

he would receive adaptive physical education, speech pathology;

and occupational therapy (id. at ¶ 2); he would then be bussed to

the local library for his special education instruction by a

District-provided special education teacher (id. at ¶ 3); and,

thereafter, AK’s parents would be responsible for his transport

home (id. at ¶ 4). As Plaintiff alleges, the 2019 Agreement became

3 The facts set forth herein are taken from the Complaint, as well as the documents attached to it as exhibits, and are accepted as true for purposes of the instant motion. Sira v. Morton, 380 F.3d 57, 67 (2d Cir. 2004).

4 The 2019 Agreement is attached to the Complaint in this action. 3

the “‘last agreed upon’ pendency agreement” between the parties.

(Compl. ¶ 12.) According to Plaintiff, A.K. received his

instruction in accordance with the terms of the 2019 Agreement “up

and until the COVID-19 pandemic ensued, wherein all instruction

became virtual.” (Id.)

In March 2020, in accordance with a COVID-19 pandemic-

related executive order from then-Governor Cuomo, Westhampton

terminated in-person instruction; thereafter, all students,

including A.K., received remote instruction through the end of the

academic year. (Pl. Opp’n at 5.) When the District began the

next school year in September 2020, it provided in-person

instruction for all elementary and middle school students. (Id.

at 6.) However, the District’s high-school students were provided

with a hybrid schedule consisting of in-person and remote

instruction. (Id.) According to Plaintiff, “all of the District’s

‘alternately assessed special education students,’ except [A.K.],

began receiving their instructions ‘full-time’ and ‘in-person’.”

(Id.)

Due to the COVID-19 pandemic, the local public library

was unavailable at the commencement of the 2020 academic year.

Accordingly, prior to the start of that academic year, the District

notified Plaintiff that because of the library’s closure due to

the pandemic, it would provide A.K.’s special education

instruction in his home. (Compl. ¶ 17.) Specifically, A.K. would

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receive daily services at the school from 7:30 a.m. to 9:00 a.m.,

and would then be bussed home where he would receive in-person

home instruction from a teacher three days per week and remote

instruction from the same teacher two days per week. (See Killoran

v. Westhampton Beach Sch. Dist., No. 20-CV-4121, 2020 WL 5424722,

at *2 (E.D.N.Y. Sept. 10, 2020) (hereafter, the “Prior Order”)

(docketed herein at ECF No. 9).) Referencing the 2019 Agreement,

Plaintiff responded to the District that it “should facilitate

such instruction within its own facilities, particularly because

it remains the [District] that is legally obligated to educate

[A.K.] and also because the [District] is doing so for every other

student.” (Compl. ¶ 18.) Plaintiff claims that the parents

“cannot reasonably, practically, or safely facilitate the

education of [A.K.] at home, particularly because both of [his]

parents work, and moreover that [A.K.’s] parents are not

comfortable with allowing someone, outside of the family, to enter

their home, unsupervised, during the Covid-19 pandemic.” (Id. at

¶ 19.) The District responded to Plaintiff’s concerns by offering

A.K. full-time remote instruction. (Prior Order, 2020 WL 5424722,

at *2.) Plaintiff responded via email stating:

[The] issue has been raised within the context of a Federal OTSC submitted yesterday. A.K. must receive his instruction at the school or alternatively at the Public Library. In any event DO NOT DROP A.K. OFF AT HOME, AS DOING SO WILL MOST CERTAINLY IMPACT HIS HEALTH, SAFETY AND WELL-BEING.

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(Id. (cleaned up; capitalization in original).)

II. Procedural Background

On September 2, 2020, Plaintiff filed the instant suit

by Order to Show Cause seeking to have A.K.’s special education

instruction take place in the District. (See Compl.) Following

a telephonic hearing on September 8, 2020, the Court issued an

oral order, and on September 10, 2020, a written decision, denying

Plaintiff’s motion for emergency injunctive relief. (See Prior

Order, 2020 WL 5424722.) The Court found that the IDEA’s stay-

put provision was not violated because the Defendants were

substantially complying with the 2019 Agreement. (Id. at *3.)

The Court further found that “even if the Court were to liberally

construe the facts as disturbing the ‘status quo’ of A.K.’s

education, it would not grant emergency relief.” (Id.) After

weighing “Plaintiff’s desire for a change in A.K.’s current

pendency placement to ease the burden of home instruction on

Plaintiff and his wife against the safety of all others in the

district,” the Court concluded that the balance of hardships did

not tip in Plaintiff’s favor. (Id.) Furthermore, the Court found

that Plaintiff failed to show irreparable harm, noting that all

students across the nation were grappling with modified learning

due to the pandemic. (Id.) Ultimately, the Court concluded that,

in light of the library’s closure due to the pandemic, Defendant’s

proposal complied with the 2019 Agreement. (Id.)

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With respect to the instant motions, Plaintiff’s

Complaint seeks an order “compelling the [District] to allocate

the space necessary to educate [A.K.],” and compensatory education

damages for a purported violation of the stay-put provision of the

IDEA. (Compl., “WHEREFORE” clause; Pl. Opp’n at 26-27.) Plaintiff

seeks additional damages for alleged violations of the ADA, Section

504, and Section 1983. (Compl., “WHEREFORE” clause.)

On October 30, 2020, Defendants filed their Dismissal

Motion asserting that the Complaint fails to state a claim pursuant

to Federal Rule of Civil Procedure 12(b)(6). (See

Dismissal

Motion.) On November 30, 2020, Plaintiff filed his opposition to

Defendants’ Dismissal Motion and cross-moved for partial summary

judgment of Plaintiff’s IDEA claim. (Pl. Opp’n.) On January 4,

2021, Defendants filed a reply brief in further support of their

Dismissal Motion and in opposition to Plaintiff’s Cross-Motion.

(Defs. Reply, ECF No. 21.) On January 13, 2021, Plaintiff filed

a reply brief in support of his Cross-Motion. (Pl. Reply, ECF No.

23.)

[Remainder of page intentionally left blank.]

7

DISCUSSION I. Standard of Review 5 To withstand a motion to dismiss, a complaint must

contain factual allegations that “state a claim to relief that is

plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678

(2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570

(2007)). This plausibility standard is not a “probability

requirement” and requires “more than a sheer possibility that a

defendant has acted unlawfully.” Id. (internal quotation marks

and citation omitted). Although the Court must accept all

allegations in the complaint as true, this tenet is “inapplicable

to legal conclusions.” Id. Thus, “[t]hreadbare recitals of the

elements of a cause of action, supported by mere conclusory

statements, do not suffice.” Id. (citation omitted). Ultimately,

the Court’s plausibility determination is a “context-specific task

5 Initially, the Court applies the Rule 12(b)(6) standard. To the extent any claim survives dismissal, the Court would then apply the summary judgment standard. However, because in this instance the Court finds that Plaintiff fails to state a claim for which relief may be granted, it need not apply the summary judgment standard. Additionally, because the Court grants Defendants’ Dismissal Motion in its entirety based on the pleadings and the properly attached documents, there is no need to consider the parties’ affidavits and accompanying exhibits submitted in support of, and in opposition to, Plaintiff’s Cross-Motion. See Staub v. Henshaw, No. 06–CV–0098, 2006 WL 1650687, at *2 (W.D.N.Y. June 7, 2006) (“[C]ourt need not consider any evidence outside the pleadings, . . . because plaintiff has failed to plead facts sufficient to state a claim.”). 8

that requires the reviewing court to draw on its judicial

experience and common sense.” Id. at 679.

In deciding a motion to dismiss, the Court is confined

to “the allegations contained within the four corners of [the]

complaint,” Pani v. Empire Blue Cross Blue Shield, 152 F.3d 67, 71

(2d Cir. 1998), but this has been interpreted broadly to include

any document attached to the complaint, any statements or documents

incorporated in the complaint by reference, any document on which

the complaint heavily relies, and anything of which judicial notice

may be taken. See Chambers v. Time Warner, Inc., 282 F.3d 147,

152-53 (2d Cir. 2002) (observing that a document is “integral” if

the complaint “relies heavily upon its terms and effect”).

Further, it is well-established that pleadings filed by

pro se plaintiffs are held “to less stringent standards than formal

pleadings drafted by lawyers[.]” Erickson v. Pardus, 551 U.S. 89,

94 (2007) (internal quotation marks and citation omitted). Where,

as here, an attorney is proceeding pro se, however, his pleadings

are not entitled to the “special consideration which the courts

customarily grant to pro se parties.” Bazadier v. McAlary, 464 F.

App’x 11, 12 (2d Cir. 2012) (internal quotation marks and citation

omitted); see Killoran v. Westhampton Beach Sch. Dist., No. 19-

CV-3298, 2020 WL 4740498, at *4 (E.D.N.Y. June 24, 2020) (“[T]he

Court takes notice that Plaintiff [Christian Killoran], although

proceeding pro se, is a registered attorney.”) report and

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recommendation adopted, 2020 WL 4743189 (E.D.N.Y. July 27, 2020).

Accordingly, although Plaintiff is proceeding pro se, his

Complaint is held to the same standards as pleadings drafted by

lawyers. See Bazadier, 464 F. App’x at 12.

II. Alleged IDEA Violation

Plaintiff claims that Defendants have violated the stay-

put provision of the IDEA and therefore seeks a permanent

injunction in the form of “an ‘equitable order’ compelling the

[District] to allocate the space necessary to educate [A.K.]” in

the District. (Compl., “WHEREFORE” clause.) Defendants contend

that Plaintiff fails to state an IDEA claim because the Complaint

fails to allege that the District breached the Agreement.

(Dismissal Motion at 15-17.) For the reasons discussed below, the

Court agrees.

A. The IDEA’s Stay-Put Provision

The IDEA’s stay-put provision provides in relevant part

that “during the pendency of any proceedings conducted pursuant to

[20 U.S.C. § 1415] . . . the child shall remain in the then-current

educational placement of the child.” 20 U.S.C. § 1415(j). The

term “then-current educational placement” in the stay-put

provision typically refers to the child’s last agreed-upon

educational program before the parent requested a due process

hearing to challenge the child’s IEP. Ventura de Paulino v. N.Y.

City Dep’t of Educ., 959 F.3d 519, 532 (2d Cir. 2020); Arlington

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Cent. Sch. Dist. v. L.P., 421 F. Supp. 2d 692, 697 (S.D.N.Y. Mar.

14, 2006) (noting that the stay-put provision is applicable to

pendency placement that arises from an agreement between the

parties) (citing Bd. of Educ. of Pawling Cent. Sch. Dist. v.

Schutz, 137 F. Supp. 2d 83 (N.D.N.Y. 2001), aff’d, 290 F.3d 476,

484 (2d Cir. 2002), cert. denied, 537 U.S. 1227 (2003))). The

stay-put provision exists to “provide stability and consistency in

the education of a student with a disability,” Arlington Cent.

Sch. Dist., 421 F. Supp. 2d at 696, and to maintain “the

educational status quo while the parties’ dispute is being

resolved.” T.M. ex rel. A.M. v. Cornwall Cent. Sch. Dist., 752

F.3d 145, 152 (2d Cir. 2014). Thus, in effect, the provision is

“an automatic injunction, which is imposed without regard to such

factors as irreparable harm, likelihood of success on the merits,

and a balancing of the hardships.” Arlington Cent. Sch. Dist.,

421 F. Supp. 2d at 696 (citing Zvi D. v. Ambach, 694 F .2d 904,

906 (2d Cir.1982)). Once a pendency placement has been

established, it can only be changed in one of four ways: (1) by an

agreement of the parties; (2) by an unappealed administrative

decision of a hearing officer; (3) by a decision of a state review

officer (“SRO”) that agrees with the child’s parents that a change

of placement is appropriate; or (4) by a court determination on an

appeal from an SRO’s decision. Schutz, 290 F.3d at 484.

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B. Application

Here, the parties agree that the last agreed upon

educational placement for A.K. is set out in the 2019 Agreement.

That Agreement provides that A.K. is to receive his special

services daily in the District followed by his special education

instruction in the local public library. (2019 Agreement ¶¶ 1-3;

Pl. Opp’n at 5.) Plaintiff concedes that until the onset of the

COVID-19 pandemic, A.K. was receiving his instruction in

accordance with the 2019 Agreement. (Compl. ¶ 12.) Plaintiff

contends, however, that since the library’s closure, Defendants

have violated the stay-put provision of the IDEA, and A.K. “has

not received any education since September.” (Pl. Reply at 6.)

Plaintiff argues that the library’s closure is a “pendency changing

event,” or, in the alternative, “implementation of the current

‘pendency agreement’ has been rendered impossible.” (Id.; Pl.

Opp’n at 8.) Thus, Plaintiff seeks to have A.K.’s “‘existing

pendency program’ [ ] implemented within [the District] until the

library re-opens.” (Pl. Opp’n at 17.) Plaintiff’s contentions

lack merit.

Plaintiff fails to allege a pendency changing event.

Admittedly, there has been no change in placement via an agreement

of the parties, an unappealed determination by a hearing officer,

a decision by the SRO, or a determination of a court. Further,

the library’s closure due to the pandemic is likely not a pendency-

12

changing event. See, e.g., J.T. v. de Blasio, 500 F. Supp. 3d

137, 187-88 (S.D.N.Y. 2020)(finding no change in pendency

placement where schools closed and switched to remote learning due

to COVID-19 pandemic) (appeal pending); see also N.D. v. Hawaii

Dep’t of Educ., 600 F.3d 1104, 1116, (9th Cir. 2010) (finding that

the shutting down of all schools in Hawaii did not constitute a

change in the educational placement of disabled children).

Plaintiff contends, however, that “even if the Court is

not inclined to view the library’s closing as being a conventional

‘pendency changing event,’” it should “view the circumstances at

hand as profiling as a seeming case of ‘first impression’

concerning pendency, brought about by the novelty of a world-wide

pandemic.” (Pl. Opp’n at 18.) Plaintiff argues that

“implementation of the current ‘pendency agreement’ has been

rendered impossible” (Id. at 8), and therefore the Court should

“reform” the 2019 Agreement and “name the [District] as the most

appropriate public situs to facilitate [A.K.’s education], at

least until the library re-opens.” (Pl. Reply at 6.)

However, because the 2019 Agreement already provides for

the contingency of the library’s closure, the Court need not

“reform” it; the relevant provision provides:

Should the library become unavailable for home instruction or special instruction, due to an emergency, a library closure, or other circumstances not caused by and beyond the control of the parties, the terms above shall

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remain operative except that the [special education] instruction . . . shall take place in [A.K.]’s home, if available. In the event the library shall be closed for a period exceeding 7 days and [A.K.]’s home is unavailable, the parties will seek in good faith to orchestrate another, alternative off- site placement location.

(2019 Agreement ¶ 8.) Thus, according to the terms of the 2019

Agreement, the library’s extended closure due to the COVID-19

pandemic required that A.K.’s special education instruction take

place in his home, if available. (Id.) In the event Plaintiff’s

home is unavailable, as he now claims, the language of the 2019

Agreement is clear: The parties are to arrange for an alternative,

off-site location. (Id. (emphasis added).)

Plaintiff claims that his home is unavailable because

A.K.’s “parents would have to quit their jobs,” “hire educational

personnel capable of implementing [A.K.’s] educational

accommodations,” “hire supervisorial staff to supervise the safety

of [A.K.],” and “[A.K.’s] family would have to avail itself to the

health risks of allowing outside people into their home during the

world-wide Covid-19 pandemic.” (Pl. Reply at 5-6.) Plaintiff

further asserts that the “[2019 A]greement clearly provides that

in circumstances where such instruction was temporarily

compromised, that [A.K.] would be brought to the [District] for

purposes of receiving his instruction.” (Pl. Reply at 5; see also

Pl. Opp’n at 21.) Plaintiff supports this claim relying upon the

14

“fall back” placement site provision regarding teacher

unavailability, as provided for in paragraph 3 of the 2019

Agreement. (Pl. Opp’n at 21-22, n.18, 19.) Plaintiff is

mistaken.

Paragraph 3 of the 2019 Agreement provides:

[i]n the event [A.K.]’s special education teacher shall cancel instruction, {A.K.] shall not be sent home, but the [District] shall, upon its discretion, either bus [A.K.] to the local library with his aide, or keep him within the [District], within a safe and appropriate space, where [A.K.] will receive carry-over activities. Under these circumstances, the [District’s] obligations to maintain [A.K.]’s presence within the local library, or within the [District] itself, shall not exceed 2 hours.

(2019 Agreement ¶ 3.) Thus, according to its terms, paragraph 3

of the Agreement applies only when the special education teacher

cancels instruction, and not in the event that the library closes

and A.K.’s home is unavailable. Moreover, the District has offered

to provide A.K.’s special education services in accordance with

the appropriate provision of the 2019 Agreement, i.e., paragraph

8. However, Plaintiff claims that his home is unavailable and

insists that A.K.’s special education instruction take place only

in the District.

The Court finds that Defendants have not violated the

stay-put provision. In fact, in an effort to accommodate

Plaintiff’s trepidations regarding having someone come into his

15

home during the COVID-19 pandemic, the District offered A.K. remote

instruction by the District’s special education teacher. (Pl.

Opp’n at 10.) Additionally, to alleviate Plaintiff’s concern about

missing work in order to supervise A.K. during home instruction,

the District provided Plaintiff the option of providing A.K.’s

special education instruction after regular school hours. (Pl.

Opp’n at 10-12.) However, Plaintiff rejected these accommodations

and made it clear that nothing short of having A.K. physically

present in the District for his special education instruction would

be acceptable. 6 (Id. at 11-12.)

Moreover, even if there was no pendency placement

agreement between the parties, “it is the [District], not the

Parents, that is authorized to decide how (and where) the Student’s

pendency services are to be provided.” Ventura de Paulino, 959

F.3d at 533-34 (stating a stay-put provision “does not eliminate

[ ] the school district’s preexisting and independent authority to

determine how to provide the most-recently-agreed-upon educational

program. . . [i]t is up to the school district, not the parent, to

decide how to provide that educational program [until the IEP

6 Notably, when schools first closed in March 2020 due to the COVID-19 pandemic, A.K. began receiving remote instruction in his home through the District. (Pl. Opp’n at 5.) He continued to receive special education services remotely during the summer. (Id.) Further, since the high school reopened for in-person instruction on a hybrid schedule, A.K. has been attending the high school for his daily services in compliance with the 2019 Agreement. (Id. at 9.) 16

dispute is resolved], so long as the decision is made in good

faith”) (internal quotations and citation omitted). Thus,

Plaintiff’s desire to have A.K.’s special education instruction

occur in the District does not obviate the District’s authority. 7

Hence, because the Court finds that the District has not

breached the 2019 Agreement regarding A.K.’s pendency placement,

the IDEA’s stay-put provision has not been violated. Therefore,

Plaintiff’s IDEA claim is DISMISSED WITH PREJUDICE. 8

III. Discrimination Claims Against the District

Plaintiff asserts that Defendants violated the ADA and

Section 504 by failing to “effectuate reasonable modifications

and/or accommodations, so as to address [A.K.]’s disability,” and

that “[i]n this regard, the [District] discriminate[d] against

[A.K.] predicated upon his disability.” (Compl. ¶¶ 22, 23.)

7 Further, although neither party has provided the Court with an update, the Court notes that it appears the local library has reopened since the parties’ dispute arose. See https://westhamptonlibrary.net/ (last visited March 8, 2022). If that is so, A.K.’s special education services can once again be provided for in the local library in accordance with the 2019 Agreement. 8 The Court notes that Plaintiff’s IDEA claim against the individual defendants is dismissed for the additional reason that there is no individual liability under the IDEA. S.W. v. Warren, 528 F. Supp. 2d 282, 298 (S.D.N.Y. 2007) (citing 20 U.S.C. § 1403(a)). Additionally, “monetary damages are not available under the IDEA.” Polera v. Bd. of Educ. of Newburgh Enlarged City Sch. Dist., 288 F.3d 478, 486 (2d Cir. 2002).

17

Plaintiff’s conclusory allegations fail to allege a discrimination

claim under either the ADA or Section 504. 9

As the standards are generally the same under either the

ADA or Section 504, courts treat claims under the two statutes

identically. Henrietta D. v. Bloomberg, 331 F.3d 261, 272 (2d

Cir. 2003); see also Rodriguez v. City of N.Y., 197 F.3d 611, 618

(2d Cir. 1999) (“Because Section 504 of the Rehabilitation Act and

the ADA impose identical requirements, we consider these claims in

tandem.”). To make out a prima facie case under the ADA or Section

504, a plaintiff must show:

(1)that [he] is a qualified individual with a disability; (2) that the defendants are subject to [the pertinent statute]; and (3) that [he] was denied the opportunity to participate in or benefit from defendants’ services, programs, or activities, or was otherwise discriminated against by defendants, by reason of [his] disability.

Harris v. Mills, 572 F.3d 66, 73-74 (2d Cir. 2009) (internal

quotation marks and citation omitted).

9 In his opposition to Defendants’ Dismissal Motion, Plaintiff appears to assert a retaliation claim. (See Pl. Opp’n at 19-20). However, a plaintiff “cannot amend h[is] complaint by asserting new facts or theories for the first time in opposition to [d]efendants’ motion to dismiss.” K.D. ex rel. Duncan v. White Plains Sch. Dist., 921 F. Supp. 2d 197, 209 n.8 (S.D.N.Y. 2013) (citation omitted). In any event, Plaintiff’s claim that “the defendant district is simply trying to exert as much ‘pressure’ upon the plaintiff, as retaliation for the plaintiff’s tangential litigation pending against the defendant district” (Pl. Opp’n at 19), fails to plead a plausible retaliation claim. 18

Notably, a violation of the IDEA, without more, is

insufficient to support a claim of disability-based discrimination

under the ADA or Section 504. See French v. N.Y. State Dep’t of

Educ., 476 F. App’x 468, 472-72 (2d Cir. 2011) (a “fail[ure] to

show that the alleged ‘discrimination’ is anything more than a

rehashing of [the plaintiff’s] allegation that the defendants

failed to provide her with a FAPE[ 10]” warrants dismissal of

plaintiff's ADA and Section 504 claims). Rather, where a plaintiff

asserts denial of a FAPE, there must be evidence that the school

district acted with “deliberate or reckless indifference to the

student’s federally protected rights” or with “bad faith or gross

misjudgment.” Pape v. Bd. of Educ. of Wappingers Cent. Sch. Dist.,

No. 07-CV-8828, 2013 WL 3929630, at *11 (S.D.N.Y. July 30, 2013)

(cleaned up); see also S.W., 528 F. Supp. 2d at 290 (“[P]laintiffs

can rely on Section 504 to claim they are denied access to a free

appropriate education, as compared to the free appropriate

education non-disabled students receive, if they can show that

Defendants acted with bad faith or gross misjudgment in the

administration of disability services.”).

Here, the parties do not dispute that A.K. is disabled

under the terms of the ADA and Section 504 or that the District is

covered by these statutes. The only question is whether Defendants

10 “FAPE” is the acronym for “free appropriate public education”. 19

failed to provide reasonable accommodations to A.K. or

discriminated against A.K. because of his disability, and in so

doing, acted with “deliberate or reckless indifference” or “bad

faith” or “gross misjudgment.” Plaintiff contends that the

District failed to make reasonable accommodations to accommodate

A.K.’s disability when it “refus[ed] to accommodate the physical

space necessary to educate [A.K.] -- namely by providing for the

physical space necessary to accommodate a desk and two chairs.”

(Pl. Opp’n at 19.) However, as discussed supra, the 2019 Agreement

governs the pendency placement of A.K., and pursuant to its terms,

the District was not required to “accommodate the physical space

necessary to educate A.K.” when the library closed.

Moreover, Plaintiff makes no allegation of bad faith or

gross misjudgment on the part of the District; rather, he baldly

alleges that “the school district’s actions reflect nothing short

of abject malice, gross indifference and/or retaliation against

the plaintiff.” (Compl. ¶ 29.) Such conclusory allegations are

insufficient to plausibly state a discrimination claim. See Iqbal,

556 U.S. at 678 (“Threadbare recitals of the elements of a cause

of action, supported by mere conclusory statements, do not

suffice.”); Y.D. v. N.Y.C. Dep’t of Educ., No. 14-CV-1137, 2016 WL

698139, at *6 (S.D.N.Y. Feb. 19, 2016) (courts “dismiss Section

504 claims that ‘are, in actuality, merely restatements of [a

plaintiff’s] IDEA claims,’ where plaintiff fails to offer any facts

20

that he ‘was denied a federal benefit because of his disability’”)

(quoting Pinn ex rel. Steven P. v. Harrison Cent. Sch. Dist., 473

F. Supp. 2d 477, 484 (S.D.N.Y. 2007) (emphasis in original); Zahran

v. N.Y. Dep’t of Educ., 306 F. Supp. 2d 204, 213 (N.D.N.Y. 2004)

(dismissing Section 504 claims because they were “substantially

the same as . . . the IDEA claim”).

Thus, Plaintiff’s discrimination claims must be

dismissed as he fails to allege that A.K. was discriminated against

on the basis of his disability. Accordingly, Plaintiff’s ADA and

Section 504 claims against the District are DISMISSED WITHOUT

PREJUDICE.

IV. Discrimination Claims Against the Individual Defendants

“Individuals in their personal capacities are not proper

defendants on claims brought under the ADA or the Rehabilitation

Act.” Keitt v. New York City, 882 F. Supp. 2d 412, 426 (S.D.N.Y.

2011) (citing Harris v. Mills, 572 F.3d 66, 72-73 (2d Cir. 2009)).

Therefore, Plaintiff’s ADA and Section 504 claims against the

individual Defendants, to the extent brought against them in their

personal capacities, must be dismissed; accordingly, said claims

are DISMISSAL is WITH PREJUDICE.

To the extent that Plaintiff alleges discrimination

claims against the Defendants in their official capacities, those

claims fail as well. The Court notes that there is a split of

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authority as to whether the ADA and Rehabilitation Act 11 provide

for liability against individual defendants in their official

capacities. See Holly v. Cunningham, No. 15-CV-284, 2016 WL

8711593, at *4 (S.D.N.Y. June 17, 2016) (collecting cases).

Regardless, even if the Court were to conclude that the individual

Defendants could be sued in their official capacity, such claims

would fail in this instance.

Plaintiff’s discrimination claims are wholly conclusory

and are not supported by any alleged facts that plausibly show

A.K. was discriminated against because of his disability. (See,

e.g., Compl. ¶¶ 22-23, 28-29, 31.) Cf. Holly, 2016 WL 8711593, at

*5 (dismissing ADA and Rehabilitation Act claims against

individual defendants in their official capacity “in the absence

of anything other than conclusory allegations”) (collecting cases

where ADA and Rehabilitation Act claims were dismissed in the

absence of allegations of defendants’ discriminatory animus or ill

will). It is well-settled that a complaint’s “[f]actual

allegations must be enough to raise a right to relief above the

speculative level.” Twombly, 550 U.S. at 555. Thus, as is the

case here, where the complaint “tenders naked assertions devoid of

further factual enhancement,” Iqbal, 556 U.S. at 678, the plaintiff

11 As a reminder: Plaintiff’s Section 504 claim is brought pursuant to the Rehabilitation Act. (See supra at 2.) For convenience, herein, the Court will use the terms “Section 504” and “Rehabilitation Act” interchangeably. 22

has not “nudged [his] claim[] across the line from conceivable to

plausible,” Twombly, 550 U.S. at 570, thereby compelling dismissal

of the complaint. See id.; see also Iqbal, 556 U.S. at 679.

Rather, having been presented with ADA and Section 504 claims

against the individual Defendants in their official capacity that

are devoid of facts which would plausibility support said claims,

dismissal of these claims is warranted. Accordingly, Plaintiff’s

ADA and Section 504 claims against the Individual Defendants in

their official capacity are DISMISSED WITHOUT PREJUDICE.

V. Section 1983 Claim Against the District

Where an IDEA claim and a Section 1983 claim are brought

simultaneously, a plaintiff must prove that a constitutional

violation occurred “outside the scope of the IDEA.” Evans v. Bd.

of Educ. of Rhinebeck Cent. Sch. Dist., 930 F. Supp. 83, 102-03

(S.D.N.Y. 1996) (citing Bonar v. Ambach, 771 F.2d 14, 18 (2d Cir.

1985)). Plaintiff cannot use Section 1983 to obtain damages for

IDEA violations absent allegations that he was 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); French v. N.Y.S. Dep’t of Educ., No. 04-CV-0434, 2010 WL

3909163, *11 (N.D.N.Y. Sept. 30, 2010) (“Plaintiff’s complaint

makes clear that the alleged Section 1983 violations are merely a

reiteration of his IDEA claims, as they attack Defendant[’s]

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alleged noncompliance with the IDEA and its effects on

Plaintiff.”), aff’d, 476 F. App’x 468 (2d Cir. 2011).

Here, Plaintiff alleges that A.K. “is entitled to the

protections afforded by 42 U.S.C. § 1983, in the event his

constitutional right of equal protection is compromised. . . .

[A.K.] is being denied the right to receive a free and appropriate

education (FAPE) as protected by the IDEA, in the same manner as

all other special education students.” (Compl. ¶ 25.) However,

the Court finds that Plaintiff fails to allege an equal protection-

based Section 1983 claim.

The Equal Protection clause mandates that government

agencies treat “all similarly situated people alike.” Harlen

Assocs. v. Inc. Vill. of Mineola, 273 F.3d 494, 499 (2d Cir. 2001)

(citing City of Cleburne v. Cleburne Living Ctr., 473 U.S. 432,

439 (1985)). While the typical equal protection claim involves

“discrimination against people based on their membership in a

vulnerable class,” the Second Circuit and the Supreme Court have

also recognized “‘class of one’” claims “‘where the plaintiff

alleges that []he has been intentionally treated differently from

others similarly situated and that there is no rational basis for

the difference in treatment.’” Id. (quoting Vill. of Willowbrook

v. Olech, 528 U.S. 562, 564 (2000) (per curiam).) The parties

agree that this is the type of equal protection claim asserted by

Plaintiff. (Cf. Defs. Reply at 19, with Pl. Opp’n at 20-21.)

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To prevail on a “class of one” claim, “the plaintiff

must point to at least one other individual whose circumstances,

aside from being treated more favorably than plaintiff, are prima

facie identical in all other respects.” MB v. Islip Sch. Dist.,

No. 14-CV-4670, 2015 WL 3756875, at *10 (E.D.N.Y. June 16, 2015)

(cleaned up). “[C]lass-of-one plaintiffs must show an extremely

high degree of similarity between themselves and the persons to

whom they compare themselves.” Clubside, Inc. v. Valentin, 468

F.3d 144, 159 (2d Cir. 2006)). To survive a motion to dismiss, a

complaint must make sufficient factual allegations in support of

this similarity requirement. See Ruston v. Town Bd. for Town of

Skaneateles, 610 F.3d 55, 59 (2d Cir. 2010) (citing Iqbal, 556

U.S. at 678). Courts require “more than a bare allegation that

other individuals were treated differently.” Vaher v. Town of

Orangetown, N.Y., 916 F. Supp. 2d 404, 435 (S.D.N.Y. 2013)

(citation omitted). “[T]he court must [ ] determine whether, based

on a plaintiff’s allegations in the complaint, it is plausible

that a jury could ultimately determine that the comparators are

similarly situated.” Id. at 434 (quoting Mosdos Chofetz Chaim,

Inc. v. Village of Wesley Hills, 815 F. Supp. 2d 679, 697-98

(S.D.N.Y. 2011)).

Plaintiff has not met this standard. Rather, by way of

example, in his Compliant, Plaintiff alleges: the District is

educating “every other student” (Compl. ¶ 18); A.K. “is entitled

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to be afforded the rights endowed by the IDEA, in the same fashion

as all other students similarly situated to him” (¶ 24); “[i]n

this case, based upon the facts at hand, [A.K.] is being denied

the right to receive a . . . FAPE . . . in the same manner as all

other special education students” (¶ 25 (parentheses omitted));

and, although managing to facilitate the education of “every other

student,” the District “cannot facilitate the education of [A.K.]

to occur within the school district” (¶ 28). These bare-bones

allegations fall well-short of providing allegations plausibly

supporting his claim that A.K. is being treated differently from

at least one other student whose circumstances are identical to

those of A.K. Indeed, Plaintiff fails to even identify another

student purportedly similar to A.K. (See Compl., in toto.) Cf.

Killoran v. Westhampton Beach Sch. Dist., No. 19-CV-6663, 2021 WL

1146078, at *5-6 (E.D.N.Y. Mar. 25, 2021) (finding Plaintiff’s

equal protection claim failed for lack of factual allegations

regarding alleged comparators).

Plaintiff’s opposition arguments are equally unavailing.

He contends that the District has re-opened and “has availed its

‘brick and mortar’ infrastructure, as well as all of its

educational resources, to its entire student body, except for the

plaintiff.” (Pl. Opp’n at 20.) He claims that “[A.K.] is

‘similarly situated’ to all of his fellow students, [and,] [i]n

particular, [A.K.] profiles as being ‘similarly situated’ to those

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‘alternately assessed special education students’ currently

receiving ‘in-person’ instruction within the defendant

[D]istrict.” (Id.) As discussed supra, wholly lacking from

Plaintiff’s Complaint are any factual allegations demonstrating

how these “alternately assessed special education students’”

circumstances are “prima facie identical” to A.K.’s. See Camac v.

Long Beach City Sch. Dist., No. 09-CV-5309, 2011 WL 3030345, at

*16 (E.D.N.Y. July 22, 2011) (dismissing “class of one” claim in

the absence of “allegations showing how another person’s

circumstances are prima facie identical to [those of the

plaintiffs’ son]”) (cleaned up); MB v. Islip Sch. Dist., 2015 WL

3756875, at *10 (“Plaintiffs’ conclusory statement that [the

comparator] is [ ] similarly situated to [plaintiff student],

without any supporting facts to suggest an extremely high degree

of similarity between [the two students] is insufficient to

establish that no rational person could regard [plaintiff

student’s] circumstances . . . to differ from those of [the

comparator] to a degree that would justify the differential

treatment.”) (internal quotations omitted); Irwin v. W.

Irondequoit Cent. School Dist., No. 16-CV-06028, 2017 WL 881850,

at *6 (W.D.N.Y. March 2, 2017) (dismissing equal protection claim

where complaint referenced “other similarly situated students” but

failed to set forth any facts explaining how those students’

circumstances were similar to plaintiff’s).

27

Likewise, Plaintiff offers no facts from which the Court

could analyze the degree of similarity between A.K. and the

“‘alternately assessed special education students’ currently

receiving ‘in-person’ instruction within the defendant district.”

(Pl. Opp’n at 20.) Therefore, Plaintiff’s equal protection claim

fails for lack of factual allegations to support his assertion

that A.K. “is ‘similarly situated’ to all of his fellow students,

[and,] [i]n particular, . . . to those ‘alternately assessed

special education students’ currently receiving ‘in-person’

instruction within the defendant district.” See Ruston, 610 F.3d

at 59 (affirming dismissal of “class of one” claim for failure to

“allege specific examples” of similarly situated comparators); see

also Killoran, 2021 WL 1146078, at *5-6 (finding plaintiff’s equal

protection claim failed given lack of factual allegations

regarding alleged comparators). With nothing more than these

conclusory allegations, Plaintiff’s equal protection-based Section

1983 claim cannot survive a motion to dismiss. Accordingly,

Plaintiff’s equal protection claim is DISMISSED WITHOUT PREJUDICE.

VI. Leave to Amend

The Second Circuit has stated that “[w]hen a motion to

dismiss is granted, the usual practice is to grant leave to amend

the complaint.” Hayden v. County of Nassau, 180 F.3d 42, 53 (2d

Cir. 1999); see also FED. R. CIV. P. 15(a)(2) (“The court should

freely give leave [to amend] when justice so requires.”).

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Plaintiff is GRANTED LEAVE TO AMEND his Complaint in

accordance with this Memorandum and Order. Any Amended Complaint

shall be filed within thirty (30) days from the date of this

Memorandum and Order and shall be titled “Amended Complaint” and

shall bear the same case number as this Memorandum and Order, i.e.,

No. 20-CV-4121(JS)(SIL). Further, because the Amended Complaint

will completely replace the original Complaint, it must include

all factual allegations and claims that Plaintiff seeks to pursue

in this case. Plaintiff is cautioned that his failure to timely

file an Amended Complaint will lead to the dismissal of his

Complaint with prejudice and the closure of this case.

CONCLUSION

Accordingly, IT IS HEREBY ORDERED that Defendants’

Dismissal Motion (ECF No. 16) is GRANTED, and Plaintiff’s Cross-

Motion (ECF No. 19) is DENIED.

SO ORDERED.

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

Dated: March 22,2022 Central Islip, New York

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E.D.N.Y.: Killoran v. Westhampton... | Special Education Law