Luna Perez v. Sturgis Public Schools
Headline: Court allows a deaf student to seek money damages under the ADA, holding special-education exhaustion is not required when the Individuals with Disabilities Education Act cannot provide the requested relief.
Holding: The Court held that IDEA’s exhaustion requirement does not bar an ADA lawsuit for compensatory damages because IDEA cannot provide money damages, so the deaf student may proceed without exhausting IDEA’s procedures.
- Allows disabled students to seek money damages under the ADA when IDEA cannot provide them.
- Allows some school-related claims to proceed without IDEA administrative hearings.
- Remands the case for further court proceedings on the ADA claim.
Summary
Background
A deaf student attended a Michigan school district from age nine through twenty. The family says the district provided unqualified interpreters, inflated his grades, and then refused to award him a diploma. They filed an administrative complaint with the state education agency and settled before a hearing, obtaining forward-looking relief like additional schooling. After settling, the student sued the district under the Americans with Disabilities Act to recover compensatory money damages for past harms, and lower courts dismissed the ADA suit as barred by IDEA’s exhaustion rule in 20 U.S.C. §1415(l).
Reasoning
The Court considered whether §1415(l) requires exhausting IDEA procedures before suing under other federal laws when the plaintiff seeks a remedy IDEA cannot provide. The Justices read the statute’s two clauses together and concluded exhaustion applies only when the plaintiff seeks relief that is also available under IDEA. Because compensatory money damages are not available under IDEA, the Court held exhaustion was not required here and reversed the Sixth Circuit in a unanimous opinion by Justice Gorsuch.
Real world impact
The ruling allows students and families to pursue ADA claims for money damages when IDEA cannot supply that relief, while leaving intact IDEA’s administrative route for claims seeking the same types of relief IDEA can grant. The case is remanded for further proceedings on the ADA claim, so this opinion decides the exhaustion question but does not resolve the underlying merits of the ADA lawsuit.
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