Judge Jack Weinstein

A.L. and R.L. sued the New York City Department of Education (DOE) on behalf of daughter T.L. who had serious learning disabilities and suffered from PICA, a neurological disorder causing her to frequently grab inedible objects and place them in her mouth. In the instant action, the parents sought reversal of a state review officer’s (SRO) decision that DOE had offered T.L. an appropriate public school education. In so doing, the SRO overruled an order of the impartial hearing officer who had granted the parents prospective payment and reimbursement by DOE for T.L.’s tuition and related educational services. Both parties moved for summary judgment, and the court denied both motions remanding the case to the SRO for further development of the administrative record and additional factfinding. The court reasoned that further analysis was required for how DOE’s proposed public school placement would have provided an educational environment that ensured T.L.’s severe PICA disorder did not interfere with her classroom instruction. The court found the record unacceptably sparse in details, and the effect of the school’s facilities and environment on T.L.’s PICA needs raised important questions of educational policy and practice.