Assistant Superintendents Are “School Officers”: Aideyan v. Mount Vernon City School District (2025) and Its Precedential Reach

Introduction

A retaining-wall collapse and subsequent flooding sparked Aideyan v. Mount Vernon City School District, but the case’s true significance lies in a procedural question: Is an Assistant Superintendent a “school officer” for purposes of personal service under CPLR 311(a)(7)?

The Appellate Division, Second Department, unanimously answered “yes,” reversing the trial court and holding that personal delivery of a summons and complaint to an Assistant Superintendent for Curriculum & Instruction satisfies service on a school district.

Parties:

Plaintiffs-Appellants: Andrew Aideyan and neighboring homeowners whose properties flooded after Hurricane Ida.
Defendant-Respondent: Mount Vernon City School District.

Key Issue on Appeal: Whether service upon Assistant Superintendent Jamal Doggett constituted valid service on the District, conferring personal jurisdiction.

Summary of the Judgment

The Second Department held that an Assistant Superintendent fits squarely within the catch-all clause of Education Law §2(13): “other elective or appointive officer in a school district whose duties generally relate to the administration of affairs connected with the public school system.”
Because CPLR 311(a)(7) allows service on “a school officer, as defined in the Education Law,” service on Doggett was valid.
The order dismissing the complaint for lack of personal jurisdiction was reversed; the action may proceed on the merits.

Analysis

Precedents Cited

Santana v. Mount Vernon City School District/Board of Education, 2023 WL 2876653 (SDNY)
– Federal court deemed an Assistant Superintendent a “school officer” under Education Law §2(13) for a Title VII action.
Guity v. Uniondale Union Free School District, 2017 WL 9485647 (EDNY)
– Recognized Assistant Superintendent as “school officer” for exhaustion-of-remedies analysis.
Knox ex rel. D.K. v. Poughkeepsie City School District, 2022 WL 305275 (SDNY)
– Held that service on an Assistant Superintendent satisfied CPLR 311(a)(7), but noted the absence of New York appellate authority—an absence now cured by Aideyan.
Cases limiting who is not a school officer (cited to contrast):
- Matter of Baumann & Sons Buses, Inc. v. Ossining UFSD, 121 A.D.3d 1110 (security guard).
- Matter of Puchalski v. Depew UFSD, 119 A.D.3d 1435 (payroll clerk).
- Matter of Franz v. Board of Educ. of Elwood UFSD, 112 A.D.2d 934 (secretary).
- Matter of Kornit, 70 A.D.2d 657, aff’d 49 N.Y.2d 842 (school attorney).
The Second Department distinguished these roles as lacking broad, district-wide administrative duties.

Legal Reasoning

The Court employed traditional tools of statutory construction:

Plain Meaning. Education Law §2(13) expressly embraces any “other elective or appointive officer … whose duties generally relate to the administration of affairs connected with the public school system.” Assistant Superintendents are created, appointed, and supervised directly by the Board of Education under Education Law §2503(5).
Whole-Text Canon. Reading §2(13) in its entirety, the enumerated positions (clerk, treasurer, superintendent, etc.) culminate in a residual clause designed to sweep in analogous officers. Applying expressio unius est exclusio alterius (the defendant’s argument) would nullify that residual clause.
Functional Analysis. Doggett’s district-wide curricular oversight mirrors the Superintendent’s core responsibilities, satisfying the “administration of affairs” criterion.
Rejection of Contrary Authority. Commissioner of Education decisions treating assistant superintendents as employees were limited to Education Law §306 removal proceedings and lacked statutory analysis relevant to service of process.
Policy Considerations. Facilitating reliable service on high-ranking officers prevents technical dismissals and promotes adjudication on the merits—consistent with New York’s liberal service and notice principles.

Impact of the Decision

Binding Precedent in the Second Department. Trial courts in Brooklyn, Queens, Staten Island, Long Island, and the lower Hudson Valley must now treat Assistant Superintendents as permissible recipients of service.
Persuasive Statewide Authority. The First, Third, and Fourth Departments often follow Second Department statutory interpretations; uniformity is likely, though a split could draw Court of Appeals review.
Practical Litigation Effect.
- Process servers gain a clearly identified target, reducing “sewer service” claims.
- School districts must train Assistant Superintendents on handling legal papers and diarying litigation deadlines.
- Early dispositive motions based on technical service defects will be curtailed, expediting substantive resolutions.
Possible Extension. The reasoning may extend to other high-level appointed positions (e.g., Deputy Superintendent, Chief Financial Officer) whose duties are district-wide and administrative in nature.

Complex Concepts Simplified

Service of Process: The formal delivery of court papers (summons and complaint) to a defendant, notifying them of a lawsuit and invoking the court’s jurisdiction.
Personal Jurisdiction: The court’s authority over a defendant. Without valid service, the court cannot bind the defendant to its judgments.
CPLR 311(a)(7): A New York procedural rule specifying how to serve school districts: delivery must be made to a “school officer, as defined in the Education Law.”
Education Law §2(13): Defines “school officer,” listing specific titles and a catch-all for other elective or appointive officers whose duties relate to administering public school affairs.
Expressio Unius Est Exclusio Alterius: Latin maxim: “the expression of one thing implies the exclusion of another.” The Court declined to apply it because the statute’s catch-all clause shows legislative intent to include analogous officers.
Assistant Superintendent: A high-level, board-appointed administrator who oversees district-wide functions (curriculum, finance, personnel, etc.) and often acts with the Superintendent’s delegated authority.

Conclusion

Aideyan v. Mount Vernon City School District settles a previously unsettled point of New York practice: Assistant Superintendents are “school officers” for purposes of service of process.

By harmonizing CPLR 311(a)(7) with Education Law §2(13) and recognizing the expansive administrative role of Assistant Superintendents, the Second Department ensures that litigants can effectively commence actions against school districts without succumbing to technical traps. The decision promotes judicial efficiency, provides clear guidance to practitioners and school administrators alike, and is poised to influence both future educational litigation and broader municipal service-of-process doctrine across the state.