WHITE PLAINS, NY – A federal judge has upheld a decision in favor of the Eastchester Union Free School District, ruling that the district provided an adequate education for a high school student with disabilities under federal law, rejecting the parents’ bid for private school tuition reimbursement.
U.S. District Judge Vincent Briccetti ruled that the parents, identified as S.M. and L.M., failed to show the district denied their child, J.M., a “free appropriate public education” (FAPE) as required under the Individuals with Disabilities Education Act (IDEA). The judge’s decision affirms a prior finding by a New York State Education Department review officer that the district’s individualized education program (IEP) for J.M. met federal standards for the 2023–2024 school year.
The case began after an impartial hearing officer initially sided with the parents, concluding that Eastchester’s proposed IEP failed to meet J.M.’s specific needs. That decision awarded the family tuition reimbursement for a private school placement. However, the district appealed, and the state review officer overturned the ruling, finding the district’s program was appropriate and the private placement unnecessary.
Judge Briccetti’s opinion, issued this week, agreed with the review officer’s reasoning, granting summary judgment to the district and denying the parents’ cross-motion. The ruling means the family will not receive public reimbursement for J.M.’s private school tuition.
Parents lose appeal in IDEA reimbursement dispute
The court reaffirmed that under the IDEA, school districts must design an IEP tailored to a child’s educational needs but are not required to provide the “best possible” program—only one that enables meaningful progress. Eastchester’s plan, the judge said, satisfied that standard.
- Parents sought private school tuition reimbursement under IDEA
- Federal judge found Eastchester’s IEP met education law requirements
- State and district decisions upholding the plan remain in effect