Supreme Court Unanimously Rules For Deaf Student Who Sued Public School For Failure To Provide Adequate Education

CATEGORY: Public Education Matters
CLIENT TYPE: Public Education
DATE: Mar 28, 2023

Petitioner Miguel Luna Perez (Perez), a deaf student, attended schools in Michigan’s Sturgis Public School District (District) for twelve years. After the District notified Perez he could not graduate, he filed an administrative complaint against the Michigan Department of Education alleging the District failed to provide free and appropriate public education as required by the Individuals with Disabilities Education Act (IDEA). Perez alleged the District supplied him with aides who did not know sign language and were not qualified to communicate in sign language and left him without interpreters for hours at a time. Additionally, he claimed the District misrepresented his educational progress by awarding him higher-than-earned grades and advancing him from grade to grade. The District told Perez that he was on track to graduate with his class. However, months before graduation, the District informed Perez and his family that it would not be awarding Perez with a diploma. Shortly before the administrative hearing, the District and Perez reached a settlement where the District promised to provide Perez with the forward-looking equitable relief he sought, including additional schooling.

After settling the administrative complaint, Perez sued the District in federal district court under the Americans with Disabilities Act (ADA) seeking damages against the District. The District moved to dismiss the case, arguing that Perez cannot assert his ADA claim because a provision in IDEA, 20 USC § 1415(l) barred from bringing the ADA claim without first exhausting all of IDEA’s administrate dispute resolution procedures. The federal district court agreed and dismissed Perez’s suit. On appeal, the Sixth Circuit affirmed the district court. However, because the courts of appeals disagreed on how to interpret the IDEA, the U.S. Supreme Court heard the case.

The Supreme Court noted that nothing in IDEA shall be construed to restrict the ability of individuals to seek remedies under the ADA or other federal laws protecting the rights of children with disabilities. However, the IDEA also prohibits certain lawsuits from being filed prior to exhausting administrative processes. The District argued that the law bars Perez’s ADA suit because it seeks relief for harms flowing from the District’s alleged past shortcomings, and Perez chose to settle his administrative complaint rather than exhaust the administrative processes. Perez argued that because the IDEA does not provide for compensatory damages, the IDEA does not foreclose his ADA claim against the District.

The Supreme Court held that the IDEA’s exhaustion provisions do not bar Perez’s ADA claim because the relief he seeks (i.e., compensatory damages) is not a remedy that the IDEA can provide. The Supreme Court reversed the Court of Appeals and remanded the case for further proceedings consistent with its opinion.

Perez v. Sturgis Public Schools, 598 U.S. ____ (2023).

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