Supreme Court’s Recent Decision: Perez v. Sturgis Public Schools
The United States Supreme Court recently issued a unanimous decision, Perez v. Sturgis Public Schools et al., which provides clarification about the Individuals with Disabilities Education Act’s (“IDEA”) exhaustion requirement under Section §1415(l). The Court held that IDEA’s exhaustion requirement did not preclude a student from separately bringing action in court under the Americans with Disabilities Act (“ADA”) for money damages – a remedy that is not available under IDEA.
Petitioner Miguel Luna Perez, a deaf student enrolled in the Sturgis Public School District for 12 years, filed an administrative complaint alleging that the district violated IDEA in its failure to provide a proper classroom aide for instruction in sign language. Further, Perez’s complaint included allegations that the district wrongly inflated his grades and misrepresented his academic progress to his parents. The district also informed Perez and his family that he would only be eligible for a certificate of completion when he believed he would earn a high school diploma.
Before the administrative hearing, the parties entered into a settlement that included additional schooling for Perez at the Michigan School for the Deaf and otherwise granted Perez all of his requested equitable relief. Following the settlement, Perez filed suit in the Western District of Michigan, seeking monetary damages under the ADA.
The district raised IDEA’s Section §1415(l), alleging that Perez was barred from bringing his ADA claim without first exhausting administrative remedies under IDEA. The district court and Sixth Circuit agreed with this view. The Sixth Circuit relied on the Supreme Court’s decision in Fry v. Napoleon Community Schools to deny Perez’s relief, but the Supreme Court noted that the case at bar presented a slightly different question that the Fry court did not address.
The Supreme Court Reverses the Sixth Circuit’s Decision
In reversing and remanding the Sixth Circuit’s decision, the Supreme Court highlighted two clauses within Section §1415(l):
“Nothing in this chapter shall be construed to restrict or limit the rights, procedures, and remedies available under the Constitution, the Americans with Disabilities Act of 1990 [42 U.S.C. 12101 et seq.], title V of the Rehabilitation Act of 1973 [29 U.S.C. 790 et seq.], or other Federal laws protecting the rights of children with disabilities, except that before the filing of a civil action under such laws seeking relief that is also available under this subchapter, the procedures under subsections (f) and (g) shall be exhausted to the same extent as would be required had the action been brought under this subchapter.”
The language above points to two central takeaways from the Court’s decision:
- IDEA Should Not Be Read to Restrict Available Remedies Under Other Laws
First, the Court highlighted that IDEA should not be read to restrict or limit “remedies” available under other federal laws, including the ADA. “Remedy” according to the Court, is defined as “the means of enforcing a right,” such as money damages under the ADA.
- Exhaustion Does Not Apply to All Suits Seeking Relief – Only Those Seeking Relief Also Available Under IDEA
Second, the Court weighed the differing views of the language “seeking relief that is also available.” The district argued that a plaintiff must exhaust administrative remedies before bringing a suit in court that seeks relief for the same “underlying harm” that IDEA addresses. Alternatively, Perez argued that the language “seeking relief” applied only if he were pursuing a remedy that IDEA could also offer, which was not present in his suit for compensatory damages. The Supreme Court agreed with Perez’s reading.
The Supreme Court noted that the limiting language of (f) and (g) “does not apply to all suits seeking relief that other federal laws provide” but instead applies “only to suits that ‘see[k] relief…also available under’ IDEA.” While Section §1415(l) includes both words “remedies” and “relief,” the Supreme Court interpreted these words to be synonymous, further supporting Perez’s reading of IDEA’s language.
While the lower courts relied on Section §1415(l) as a barrier to Perez’s ADA claim, the Supreme Court provided one final, succinct reminder: “We clarify that nothing in that provision bars his way.”
If you have questions about this decision or would like additional information, please contact Vickie Coe, Jordan Bullinger, Bailey Kadian, or any other member of our Education team.
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