A Manhattan federal judge (Jessica Clarke) held in Board of Education v. E.L. that New York City cannot exclude the Judaic‑studies portion of tuition when reimbursing parents for a special‑needs placement at a religious school under the Individuals with Disabilities Education Act. The ruling relies on recent Supreme Court precedents against faith‑based exclusions in neutral programs and challenges a common practice in multiple states (and a cited federal regulation) that withholds funding for religious instruction.
— It advances the post‑Carson/Espinoza line by applying it to special education, likely forcing policy changes across states that dock or deny reimbursements for religious coursework.
Michael A. Helfand, Nicole Stelle Garnett, Sydney Altfield
2025.10.09
100% relevant
Judge Clarke’s decision in Board of Education v. E.L. rejecting NYC’s deduction of Judaic Studies from IDEA tuition reimbursement at the SINAI School.
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