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Mattera v. Westhampton Beach School District — 2d Cir. (Oct 22, 2026)

No. 25-2554 Argued October 22, 2026 Published October 24, 2026

Justin Mattera, a special-education mathematics teacher, challenges the dismissal of his case against the Westhampton Beach School District. He alleges that he repeatedly objected to removing students with disabilities from integrated math classes, where students with and without disabilities learned together. He believed the separate instruction was less rigorous and involved inflated grades. Mattera says administrators then reassigned him to four resource-room periods and a non-Regents mathematics class. Resource rooms provide supplementary academic support. He describes the change as less prestigious and more burdensome. The school district denies that the reassignment was retaliation. The district court accepted his advocacy as protected activity but dismissed the case before trial, finding his retaliation allegations legally insufficient. This was a ruling on the complaint, not a trial finding that the students had been unlawfully segregated or that the reassignment was retaliatory. The Americans with Disabilities Act separately prohibits retaliation for opposing disability discrimination and coercion or interference with protected rights, including helping others exercise them. Those are distinct provisions, not automatically interchangeable claims. An I E P, also mentioned in the argument, is an individualized education program: a written plan specifying a student with a disability's educational needs, goals and services. Two Supreme Court decisions frame the dispute over harm. Muldrow concerned employment discrimination under Title Seven and required some harm to employment terms or conditions, not significant harm. Burlington Northern addressed retaliation: the action must be materially adverse, meaning it could deter a reasonable worker from making or supporting a discrimination complaint. Context matters: not every unwanted reassignment qualifies, and a pay cut is not required. Temporal proximity means how close events are in time. The timing of complaints and reassignment may support an inference of retaliation, but timing is not automatically proof of motive. Here, the sequence of repeated complaints matters, not just the first objection.

Mattera v. Westhampton Beach School District (No. 25-2554) — U.S. Court of Appeals for the Second Circuit, argued October 22, 2026.

Sources
Argument audio — official Second Circuit recording:https://ww3.ca2.uscourts.gov/audio/25-2554.mp3
Case and argument date — official Second Circuit archive:https://ww3.ca2.uscourts.gov/oral_arguments.html
Case allegations and dismissal — original district Memorandum and Order, Doc. 22, September 30, 2025 (public court-filing archive copy):https://archive.org/download/gov.uscourts.nyed.509313/gov.uscourts.nyed.509313.22.0.pdf
Retaliation and interference — 42 U.S.C. 12203:https://www.law.cornell.edu/uscode/text/42/12203
Motion to dismiss — Federal Rule of Civil Procedure 12(b)(6):https://www.law.cornell.edu/rules/frcp/rule_12
Discrimination and transfer-related harm — Muldrow v. City of St. Louis:https://www.law.cornell.edu/supremecourt/text/22-193
Materially adverse retaliation — Burlington Northern & Santa Fe Railway Co. v. White:https://www.law.cornell.edu/supct/html/05-259.ZO.html
Resource-room program definition — New York regulation 200.1(rr):https://www.nysed.gov/special-education/section-2001-definitions
Individualized education program — 20 U.S.C. 1414(d):https://www.law.cornell.edu/uscode/text/20/1414

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