Miguel Luna Perez attended schools in Michigan’s Sturgis Public School District from ages nine through 20. Because Perez is deaf, the District provided him with aides to translate classroom instruction into sign language. Perez and his parents alleged that the aides were either unqualified or absent from the classroom for hours on end. One aide allegedly attempted to teach herself sign language. Along the way, the District purportedly awarded Perez inflated grades and advanced him from grade to grade, regardless of his progress. Based on the District’s misrepresentations, Perez and his family believed Perez was on track to graduate from high school with his class, but then, months before his graduation, the District revealed it would not award him a diploma.
In response, Perez and his family filed an administrative complaint with the Michigan Department of Education alleging that the District failed to provide Perez with free and appropriate public education, as required by the Individuals with Disabilities Education Act (IDEA). The parties reached a settlement, under which the District promised to provide all forward-looking equitable relief Perez sought, which included additional schooling at the Michigan School for the Death.
After settling his administrative complaint, Perez filed a lawsuit under the Americans with Disabilities Act (ADA), seeking backward-looking relief in the form of compensatory damages. The District sought to dismiss the case, arguing that under IDEA, specifically, 20 U. S. C. §1415(l), Perez could not bring an ADA claim without first exhausting all of IDEA’s administrative dispute resolution procedures. The trial court agreed and dismissed the suit. The Court of Appeals for the Sixth Circuit affirmed the trial court’s holding. Perez appealed to the Supreme Court.
Section 1415(l) of IDEA notes that nothing restricts the abilities of individuals to seek “remedies” under the ADA or “other Federal laws protecting the rights of children with disabilities.” The statute also offers an exception about exhausting administrative processes before bringing a civil action under other federal laws. The parties disagree about what this exception means. Perez reads the exception as requiring a plaintiff to exhaust the administrative processes only to the extent a plaintiff pursues a suit under another federal law for remedies IDEA also provides. As a result, Perez argues that his ADA claim is not foreclosed because he only seeks compensatory damages, which IDEA cannot supply. The District reads the exception as requiring the plaintiff to exhaust administrative claims before pursuing another suit under another federal law if the suit seeks relief for the same underlying harm IDEA exists to address. As a result, the District argued that Perez could not bring a claim under the ADA.
The Supreme Court believed that Perez’s view better aligned with the statute’s terms. It viewed the administrative exhaustion requirement as only applying to suits that seek relief also available under IDEA. Here, Perez brought a suit under another federal law for compensatory damages, a form of relief that is not provided under IDEA. The Supreme Court noted that the District’s concern in ruling for Perez might frustrate Congress’ wish to route claims about educational services to administrative agencies with special expertise in such matters. However, that was not enough for the Supreme Court to interpret the text of the IDEA differently.
The Supreme Court reversed the holding and remanded the case back to the lower courts to determine whether the damages that Perez sought are available under the ADA.
Luna Perez v. Sturgis Public Schools (2023) 143 S.Ct. 859.
Note: While this case concerns a public school district and does not apply to private schools, it provides helpful guidance to private school practices on certain best practices, such as keeping parents informed on students’ progress, checking that reasonable accommodations are appropriately supporting students’ functional limitations, and uniformly and consistently applying academic standards.