Arje v. Aviles-Ramos

Background

Sylvia Arje, Massiel de la Cruz, and Patrick Donohue are parents and guardians of three students with disabilities enrolled at the International Institute for the Brain, referred to as iBRAIN. They sued the New York City Department of Education and its then-Chancellor, David C. Banks, under the Individuals with Disabilities Education Act. They alleged that the Department and Chancellor failed to implement or comply with final administrative orders that fully funded the students’ attendance at iBRAIN.

The plaintiffs asked for a preliminary injunction, which is a temporary court order issued before the final resolution of a case. They wanted the defendants to immediately fund the students’ placements at iBRAIN.

Court’s Analysis

To obtain a preliminary injunction, the plaintiffs had to show, among other things, that they were likely to suffer irreparable harm without immediate relief. Irreparable harm means harm that cannot adequately be repaired later through money damages. The court described this showing as the most important requirement for a preliminary injunction.

The defendants argued that the plaintiffs had provided no declaration or exhibit showing that the students’ educational placements were at risk or would be interrupted without immediate payment. The court agreed. It found that the plaintiffs focused on unpaid amounts and alleged broader Department wrongdoing, but did not present evidence that the students’ continued enrollment at iBRAIN had been jeopardized.

The court concluded that the dispute concerned educational funding rather than the students’ placements. Because the plaintiffs had not shown that delayed payments would affect the students’ educational services or placements, the court held that they had not demonstrated irreparable harm. The court therefore did not reach the parties’ other arguments concerning the preliminary injunction.

Ruling and Further Proceedings

The court DENIED the plaintiffs’ Motion for a Preliminary Injunction. It directed the parties to meet and confer in good faith about any outstanding balances owed to the plaintiffs and/or iBRAIN. The parties were ordered to file a joint status letter by June 16, 2025, describing any remaining issues and proposing next steps. The court also directed the Clerk to substitute Chancellor Melissa Aviles-Ramos for Chancellor David C. Banks as a defendant under Federal Rule of Civil Procedure 25(d), and to update the docket. Judge Ho did not resolve the underlying claims under the Individuals with Disabilities Education Act in this order.