A unanimous U.S. Supreme Court ruled in favor of a deaf student in Michigan and reinstated his Americans with Disabilities Act lawsuit, finding the Individuals with Disabilities Education Act’s exhaustion requirement didn’t preclude him from seeking compensatory damages under ADA.
The March 21 eight-page opinion in Luna Perez v. Sturgis Public Schools, authored by Justice Neil Gorsuch, reversed a ruling from the 6th Circuit Court of Appeals.
Miguel Luna Perez was a student from age nine through 20 at Michigan’s Sturgis Public School District. As a deaf student, Perez was provided with in-classroom sign language interpreters but his parents claimed the interpreters were either unqualified or absent for extended periods of time.
His parents also alleged the school district advanced him through grades and inflated his class scores which led them to believe he was on track to graduate high school. They also claim that months before graduation the school informed them Perez wouldn’t get a diploma.
Perez and his family filed a complaint with the Michigan Department of Education claiming the school district failed in its duties under IDEA. The complaint ended in a settlement where the school district promised to provide forward-looking equitable relief and additional schooling at the Michigan School for the Deaf.
The family and Perez then filed a federal lawsuit under ADA seeking compensatory damages, a backward-looking form of relief. A district court dismissed the complaint, siding with the school district that a provision of IDEA required Perez to exhaust all administrative dispute resolution routes before filing an ADA claim.
The 6th Circuit Court of Appeals affirmed the dismissal, relying on its previous holdings in 2000’s Covington v. Knox County School System. On appeal to the U.S. Supreme Court, Perez argued the compensatory damages he sought aren’t available under IDEA and therefore his ADA claims weren’t foreclosed.
The U.S. Supreme Court in October 2022 agreed to hear the appeal and resolve two questions: Can courts and under what circumstances refuse to apply the further exhaustion requirement of IDEA if doing so would be futile? And, does IDEA require administrative exhaustion for monetary damages not available under it?
The court only answered the second question, finding Perez’s case didn’t offer the opportunity to address what circumstances a court can refuse to apply the exhaustion requirement.
Tuesday’s opinion found that nothing in IDEA prevents “Mr. Perez’s ADA lawsuit because the relief he seeks (i.e., compensatory damages) is not something IDEA can provide.”
In coming to that conclusion, the Supreme Court interpreted two provisions of IDEA. The first stated nothing in IDEA should be construed to restrict seeking remedies under other federal laws that protect the rights of children with disabilities and the second carves out an exception that federal civil actions looking for remedies available under the IDEA can’t be filed until IDEA’s procedures are exhausted.
Together, the court read those clauses to provide “children and families the right to a ‘due pro- cess hearing’ before local or state administrators, followed by an ‘appeal’ to the state education agency.” The court found nothing under IDEA would block Perez’s lawsuit since he sought damages that aren’t available under the law.
The Supreme Court reversed the 6th Circuit’s findings and ordered lower courts to reinstate the case on remand.