Perez v. Porter

── Perez v. Porter ── Court: Court of Appeals for the Second Circuit Date: June 10, 2026 Category: General 25-246-cv Perez v. Porter UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE P`ROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 10th day of June, two thousand twenty-six. PRESENT: JOSÉ A. CABRANES, BARRINGTON D. PARKER, RAYMOND J. LOHIER, JR., Circuit Judges. ------------------------------------------------------------------ MARINA PEREZ, AS PARENT AND NATURAL GUARDIAN OF C.P. AND INDIVIDUALLY, Plaintiff-Appellant, v. No. 25-246-cv MEISHA PORTER, IN HER OFFICIAL CAPACITY AS THE CHANCELLOR OF THE NEW YORK CITY DEPARTMENT OF EDUCATION, NEW YORK CITY DEPARTMENT OF EDUCATION, Defendants-Appellees. ------------------------------------------------------------------  FOR PLAINTIFF-APPELLANT: RORY J. BELLANTONI, Liberty & Freedom Legal Group, New York, NY FOR DEFENDANTS-APPELLEES: JONATHAN A. POPOLOW (Richard P. Dearing, Ingrid R. Gustafson, on the brief), of Counsel, for Muriel Goode-Trufant, Corporation Counsel of the City of New York, New York, NY Appeal from a judgment of the United States District Court for the Southern District of New York (Vernon S. Broderick, Judge). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment of the District Court is AFFIRMED. Plaintiff Marina Perez, individually and on behalf of her son C.P., appeals from the January 3, 2025 judgment of the United States District Court for the Southern District of New York (Broderick, J.) granting summary judgment in favor of Defendants on Perez’s claim arising under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1400 et seq. In granting summary judgment, the District Court upheld the decision of a State Review Officer (“SRO”), which in turn affirmed the decision of an Impartial Hearing Officer. We assume the parties’ familiarity with the underlying facts and the record of prior proceedings, to which we refer only as necessary to explain our decision to affirm. 2  Mindful that courts lack the “specialized knowledge and educational expertise” of state administrators, we conduct a “circumscribed de novo review of a district court’s grant of summary judgment in the IDEA context,” seeking only to “independently verify that the administrative record supports the district court’s determination.” M.W. ex rel. S.W. v. N.Y.C. Dep’t of Educ., 725 F.3d 131, 138 (2d Cir. 2013). As an initial matter, Perez argues that the Individualized Education Program (“IEP”) was procedurally deficient because (1) Defendant New York