Luna Perez v. Sturgis Public Schools
The Supreme Court unanimously ruled that a deaf student who settled his special-education complaint can sue for money damages under the Americans with Disabilities Act without first going through the Individuals with Disabilities Education Act's administrative process.
The decision turns on the fact that IDEA's exhaustion requirement only kicks in when a plaintiff seeks a remedy IDEA can actually provide — and because IDEA cannot award money damages, that hurdle simply never applies here.
“In proceedings below, the courts held that § 1415(l) precluded Mr. Perez's ADA lawsuit. We clarify that nothing in that provision bars his way.”
The Court's bottom-line conclusion removing IDEA's exhaustion requirement as an obstacle to Perez's ADA lawsuit.
How it got here: A federal district court dismissed Perez's ADA suit; the Sixth Circuit affirmed based on its own prior precedent; Perez asked the Supreme Court to step in and the Court agreed to hear the case to resolve a split among federal appeals courts.
The Case in Depth
What happened
Miguel Luna Perez, who is deaf, attended Michigan's Sturgis Public School District from ages 9 to 20. He alleges Sturgis provided him with unqualified sign-language interpreters, misrepresented his grades and educational progress, and then — months before his expected graduation — told him he would not receive a diploma. He and his family settled a special-education administrative complaint, winning future schooling, then separately sued Sturgis for money damages under the Americans with Disabilities Act.
The question before the Court
Can a disabled student who seeks money damages — which special-education law cannot provide — skip special-education law's administrative complaint process and go straight to court under a separate civil rights law?
The Court's answer
No — the Court ruled that nothing in IDEA's exhaustion requirement blocks Perez's ADA lawsuit. The exhaustion rule only applies when a plaintiff seeks a remedy that IDEA can also provide. Perez seeks compensatory money damages, and both sides agree that IDEA cannot award money damages at all — so the condition that triggers exhaustion is simply never met.
The Court reached this by reading the statute's key phrase — "seeking relief that is also available under" IDEA — to refer to the specific type of remedy a plaintiff requests, not to whether the underlying grievance generally falls within IDEA's subject matter. Because money damages are outside what IDEA can offer, the administrative exhaustion requirement does not stand in the way of Perez's ADA claim.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Students with disabilities who want to sue schools for money damages under federal civil rights laws can now do so without first running through a separate special-education administrative process — as long as the damages they seek are ones that special-education law cannot itself award. This removes a significant procedural barrier that had been applied differently across different federal courts.
What changes now
The case is sent back to the lower courts to address questions the Supreme Court did not reach — most importantly, whether the ADA actually provides compensatory damages to Perez and whether any other legal barriers apply. The ruling removes only IDEA's exhaustion requirement as an obstacle; Perez still must litigate the merits of his ADA claim before any award of damages is possible.
What this does not decide
The Court did not decide whether IDEA's exhaustion requirement has a judge-made exception for cases where going through the process would be futile, or whether the ADA actually allows compensatory damages in a case like Perez's. Both questions return to the lower courts on remand.
How the Court got there
The legal reasoning, step by step
- IDEA § 1415(l) has two parts: a general rule that nothing in IDEA limits a student's ability to seek remedies under other federal disability laws, followed by an exception requiring administrative exhaustion before filing a lawsuit that seeks 'relief that is also available' under IDEA. The whole case turned on interpreting that exception.
- The Court faced two competing readings: Perez argued exhaustion only applies when the specific remedy he requests is also available under IDEA; Sturgis argued exhaustion applies whenever the underlying grievance — here, deficient special education — is the kind of harm IDEA exists to address. The Court chose Perez's reading as more consistent with the statute's text.
- The Court noted that IDEA itself uses the words 'remedies' and 'relief' interchangeably in multiple other provisions, strongly suggesting that 'seeking relief' in the exhaustion exception refers to the specific remedy a plaintiff requests — not to the general subject matter of the lawsuit. Other parts of the U.S. Code and Federal Rule of Civil Procedure 8(a)(3), which requires a 'demand for the relief sought,' reinforce this ordinary usage.
- Because IDEA cannot provide compensatory money damages — a fact both parties agreed on — the exhaustion condition ('relief also available under IDEA') is never satisfied by Perez's ADA claim. There is nothing for IDEA's administrative process to supply, so requiring him to go through it would serve no purpose the statute contemplates.
- The Court distinguished Fry v. Napoleon Community Schools (a 2017 decision addressing a related but different exhaustion question), which had explicitly reserved this exact issue. The Court also rejected Sturgis's argument that routing education disputes to administrative experts should override the plain text, reaffirming that courts apply the law as written rather than speculate about congressional goals.
Doctrinal impact
Cases affected by this decision
Distinguishes Fry v. Napoleon Community Schools (580 U.S. 154)
Fry reserved this exact question rather than decided it, so it does not control here.