Payne v. Peninsula School District

The Individuals with Disabilities Education Act (IDEA) requires remedy exhaustion under 20 U.S.C. § 1415(l) when (1) there is an IDEA claim or a functional equivalent, (2) if plaintiff seeks prospective injunctive relief to alter their Individual Education Program, or (3) if plaintiff is seeking to enforce rights that arise as a result of a denial of public education. In addition the exhaustion requirement is a claims processing provision and not a jurisdictional requirement.

Payne filed suit against defendants alleging a violation under IDEA as well as other § 1983 and state law claims. The district court granted summary judgment to defendants for all claims, finding that the court lacked subject matter jurisdiction because Payne failed to exhaust her administrative remedies as required by IDEA. Plaintiff appealed, a divided panel of the Ninth Circuit affirmed. The Ninth Circuit then granted a petition to hear this case en banc. The Ninth Circuit held that the exhaustion requirement found in the IDEA statute was a “claims processing provision” rather than a jurisdictional requirement because nothing in the IDEA statute related to subject matter jurisdiction. In addition, the Ninth Circuit overruled any prior cases to the contrary and noted that this ruling was in line with the Seventh and Eighth Circuits. Next, the Ninth Circuit held the exhaustion requirement found in 20 U.S.C. § 1415(l) should be analyzed from a “relief centered approach” as opposed to an “injury centered approach.” The Ninth Circuit noted that relief sought to provide for remedies available under IDEA would be subject to the exhaustion requirement. The Ninth Circuit affirmed the district court’s granting of summary judgment for plaintiff’s IDEA claim and reversed the judgment for all other claims. AFFIRMED in part, REVERSED in part and REMANDED.