supreme court

It’s unanimous. All nine Supreme Court justices ruled in favor of the plaintiff, Miguel Luna Perez, in Perez v. Sturgis Public Schools, allowing him to pursue damages claims under the Americans with Disabilities Act without first exhausting the process required by the Individuals with Disabilities Education Act (IDEA).

The court held that IDEA’s exhaustion requirement does not preclude the ADA lawsuit because the relief Perez seeks (i.e., compensatory damages) is not something IDEA can provide.

This opens the door for other disabled students who feel their schools have failed them. The outcome “holds consequences not just for Mr. Perez but for a great many children with disabilities and their parents,” Justice Neil Gorsuch wrote for the unanimous court.

However, notes, the ruling does not address whether IDEA’s requirement to exhaust its administrative process “can be sidestepped in cases where completing the process would be ‘futile’ and whether ADA should provide financial compensation to Miguel Perez, the plaintiff.”

Perez, who is deaf, attended schools in Michigan’s Sturgis Public School District from ages 9 through 20. He was denied a Free Appropriate Public Education (FAPE) for years, reports, with the district advancing him “from grade to grade and inflat[ing] his grades to the point he repeatedly made honor roll, even though he couldn’t read or write — and then just before graduation told his family he would receive a certificate of completion but not a high school diploma.”

According to the court’s written opinion, when Sturgis announced that it would not permit Perez to officially graduate, he and his family filed an administrative complaint with the Michigan Department of Education alleging (among other things) that Sturgis failed to provide him a free and appropriate public education as required by the IDEA. (They claimed that Sturgis supplied Mr. Perez with unqualified interpreters and misrepresented his educational progress.)

The parties reached a settlement in which Sturgis promised to provide the forward-looking relief Perez sought, including additional schooling. Perez then sued in federal district court under the Americans with Disabilities Act (ADA) seeking compensatory damages. Sturgis moved to dismiss, claiming that Perez was barred from bringing his 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.

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