
    G.W., Individually and as Parent of B.W., a Minor Under the Age of 18 Years, B.W., D.W., Individually and as Parent of B.W., a Minor Under the Age of 18 Years, Plaintiffs-Appellants, v. RYE CITY SCHOOL DISTRICT, Defendant-Appellee.
    No. 13-1352.
    United States Court of Appeals, Second Circuit.
    Feb. 11, 2014.
    Peter D. Hoffman (Jamie Mattice, on the brief), Law Office of Peter D. Hoffman, P.C., Katonah, NY, for Appellants.
    Ralph Demarco, Keane & Beane, P.C., White Plains, NY, for Appellee.
    
      PRESENT: DENNIS JACOBS, GUIDO CALABRESI, and ROSEMARY S. POOLER, Circuit Judges.
   SUMMARY ORDER

G.W. and D.W., on behalf of themselves and their son, B.W., appeal from the judgment of the United States District Court for the Southern District of New York (Ramos, J.), granting summary judgment in favor of defendant-appellee Rye City School District. The appellants seek tuition reimbursement under the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq. They also seek sanctions imposed on the school district for spoliation of evidence. We assume the parties’ familiarity with the underlying facts, the procedural history, and the issues presented for review.

We review de novo a district court’s award of summary judgment in an IDEA case. A.C. ex rel. M.C. v. Bd. of Educ., 553 F.3d 165, 171 (2d Cir.2009). In doing so, we recognize that “the role of the federal courts in reviewing state educational decisions under the IDEA is ‘circumscribed.’ ” Gagliardo v. Arlington Cent. Sch. Dist., 489 F.3d 105, 112 (2d Cir.2007) (quoting Muller v. Comm. on Special Educ., 145 F.3d 95, 101 (2d Cir.1998)). “A reviewing court must engage in an independent review of the administrative record and make a determination based on a preponderance of the evidence. But such review is by no means an invitation to the courts to substitute their own notions of sound educational policy for those of the school authorities which they review.” M.H. v. N.Y.C. Dep’t of Educ., 685 F.3d 217, 240 (2d Cir.2012) (internal quotation marks and citations omitted).

A parent challenging an Individualized Education Program (“IEP”) is entitled to reimbursement of private school tuition if: 1) the services offered by the district were inadequate to provide an appropriate public education; 2) the services selected by the parents were appropriate to the child’s needs; and 3) equitable considerations support the claim. See Sch. Comm. of Town of Burlington, Mass. v. Dep’t of Educ. of Mass., 471 U.S. 359, 368-74, 105 S.Ct. 1996, 85 L.Ed.2d 385 (1985); Walczak v. Fl. Union Free Sch. Dist., 142 F.3d 119, 129 (2d Cir.1998).

In regard to spoliation, sanctions may be imposed if: 1) “the party having control over the evidence had an obligation to preserve it at the time it was destroyed;” 2) “the records were destroyed with a culpable state of mind;” and 3) “the destroyed evidence was relevant to the party’s claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Zubulake v. UBS Warburg LLC, 229 F.R.D. 422, 430 (S.D.N.Y.2004) (citing Byrnie v. Town of Cromwell, 243 F.3d 93, 107-12 (2d Cir.2001)).

We have conducted an independent and de novo review of the record. For substantially the reasons stated by the district court in its thorough opinion of March 29, 2013, we conclude that 1) the proposed IEPs for the 2008-09 and 2009-10 school years were adequate to afford B.W. an appropriate public education, and 2) the school district did not engage in spoliation of evidence.

For the foregoing reasons, and finding no merit in the appellants’ other arguments, we hereby AFFIRM the judgment of the district court. 
      
      . Because we conclude that there is no evidence in the record to support the parents’ spoliation claim, we need not, and do not, decide whether spoliation claims are cognizable in the context of IDEA appeals.
     