In a unanimous decision, the Supreme Court has held that the failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA) does not bar a separate lawsuit for compensatory damages under the Americans with Disabilities Act (ADA).
The family of a deaf student who attended public school in Michigan from ages 9 through 20 filed an administrative complaint against the school district after it announced the student would not be permitted to graduate. The complaint alleged that the district failed to provide him a free and appropriate public education as required by the IDEA.
The family claimed that the district supplied the student with unqualified interpreters and misrepresented his educational progress. The parties reached a settlement in which the district promised to provide additional schooling. The student then sued in federal district court under the ADA seeking compensatory damages.
The district sought dismissal, arguing that the IDEA provision, 20 U. S. C. §1415(l), barred the ADA claim because it requires a plaintiff “seeking relief that is also available under” IDEA to first exhaust IDEA’s administrative procedures. The district court agreed and dismissed the suit, and the Sixth Circuit affirmed.
The Supreme Court reversed and held that IDEA’s exhaustion requirement did not preclude the ADA lawsuit because the relief he seeks (i.e., compensatory damages) is not something IDEA can provide. According to the Court, because §1415(l)’s exhaustion requirement applies only to suits that “see[k] relief . . . also available under” IDEA, it poses no bar where a non-IDEA plaintiff sues for a remedy that is unavailable under IDEA. The Court reversed the judgment in favor of the district and remanded the case back to the trial court for further proceedings.
The case is Perez v. Sturgis Public Schools and it was decided on March 21, 2023.
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