The U.S. Court of Appeals for the Second Circuit issued a summary order on January 27, 2026, affirming a district court judgment against a New York City parent who challenged actions by the city's Department of Education.

In *Thomason v. Banks*, Shannon Thomason, acting individually and as parent and natural guardian of a minor identified as E.P., brought suit against David C. Banks in his official capacity as Chancellor of the New York City Department of Education, along with the Department of Education itself. The three-judge panel consisting of Circuit Judges Barrington D. Parker, Susan L. Carney, and Beth Robinson unanimously affirmed the January 28, 2025 judgment entered by Judge Lewis J. Liman of the U.S. District Court for the Southern District of New York.

The appeals court's decision came in the form of a summary order, which carries specific limitations under federal appellate procedure. According to the court's notice, "rulings by summary order do not have precedential effect," meaning this decision cannot be cited as binding authority in future cases. However, Federal Rule of Appellate Procedure 32.1 and the Second Circuit's Local Rule 32.1.1 permit citation to summary orders filed after January 1, 2007, provided parties include proper notation and serve copies on unrepresented parties.

Thomason was represented by attorney Rory J. Bellantoni of Liberty & Freedom Legal Group in New York. The defendants were represented by a team from the New York City Law Department, including Jonathan Schoepp-Wong, Richard Dearing, and Jamison Davies, working under Corporation Counsel Muriel Goode-Trufant.

While the summary order does not detail the specific claims or legal theories involved in the case, the parties' identities suggest the dispute involved educational policies or decisions affecting the minor E.P. within the New York City public school system. Thomason's dual capacity as both an individual plaintiff and as guardian of E.P. indicates the case likely concerned both her own interests and those of her child in relation to the Department of Education's actions.

Chancellor Banks, who has led the nation's largest school district since 2022, was named in his official capacity, meaning the lawsuit challenged his actions as a government official rather than in his personal capacity. This procedural distinction is significant in federal civil rights litigation, as it determines what remedies are available and what defenses the government may raise.

The Second Circuit's affirmance means the district court's ruling in favor of the defendants stands. The appeals court found no reversible error in Judge Liman's January 2025 decision, though the summary order format provides no insight into the appellate court's reasoning or the specific legal issues that were contested on appeal.

Summary orders represent one way federal appeals courts manage their heavy caseloads while providing resolution to parties. These orders typically address cases where the legal issues are well-settled or where the facts clearly support the lower court's decision. The Second Circuit, which covers New York, Connecticut, and Vermont, issues hundreds of summary orders annually alongside its precedential opinions.

The case reflects ongoing tensions between parents and school districts over educational policies and procedures. While the specific nature of Thomason's claims remains unclear from the available record, such disputes often involve issues like special education services, disciplinary actions, curriculum decisions, or administrative procedures affecting students.

For Thomason, the affirmance represents the end of her federal court challenge unless she seeks further review. The Supreme Court could theoretically hear the case if she petitions for certiorari, though the high court accepts very few such petitions, particularly in education cases that don't present novel legal questions or conflicts between circuit courts.

The timing of the district court's original January 2025 judgment and the appeals court's January 2026 affirmance reflects typical appellate processing times in the Second Circuit. The one-year timeframe from judgment to appellate resolution is consistent with standard federal appellate practice for cases decided on summary order.

For the New York City Department of Education, the victory provides validation of its position and protects whatever policies or decisions were at issue in the case. As the largest school district in the United States, serving over one million students, the Department of Education faces regular legal challenges from parents, advocacy groups, and other stakeholders.

The case also highlights the role of summary orders in federal appellate practice. While these decisions resolve individual disputes, they contribute little to the development of legal precedent, leaving future litigants with similar claims to rely on other authorities when crafting their arguments.

The resolution of *Thomason v. Banks* adds to the substantial body of education-related litigation that flows through federal courts annually, though its summary order status means it will have limited impact beyond the immediate parties involved.