general obligation for compliance with the Act, alter the court’s finding that neither the commissioner nor the State Education Department, which the Commissioner heads, are proper parties to an action pursuant to § 1415(i)(2)(A) to review a decision by a local school board regarding a disabled student’s IEP. See Bruschini, 1995 WL 807107, at *2 (general supervision of public education in state by New York Commissioner of Education insufficient basis to render Commissioner defendant to IDEA action challenging an IEP). Despite the existence of such general supervisory authority, courts recognize the preeminence of local school boards under New York’s scheme for the provision of public education in the state. See Gulino v. New York State Educ. Dep’t., 460 F.3d 361, 365 (2d Cir.2006) (<HOLDING>) (quoting Levittown Union Free Sch. Dist. v.
holding jurisdiction over nonresident defendant existed where note was payable in new york contained new york choice of law clause and proceeds were used to finance new york limited partnership holding that a company registered with the new york department of state is found for purposes of rule b holding that outofstate defendants transmittal into new york of ceaseanddesist letter to new york plaintiff for purported trademark infringement was insufficient to create jurisdiction over defendant in a new york declaratory judgment action holding that a deprivation of a constitutionally protected property interest  was not clearly established by analyzing new york court of appeals decisions even with a binding federal decision on point citing economico v village of pelham 50 ny2d 120 428 nys2d 213 405 ne2d 694 1980 prue v hunt 78 ny2d 364 575 nys2d 806 581 ne2d 1052 1991 holding state education department not a party to title vii action against new york city school board based on specific supervisory powers by state education department absent direct control over daytoday operations of school board and citing paynter v new york 100 ny2d 434 765 nys2d 819 797 ne2d 1225 1229 2003