Perez v. Sturgis Public Schools

“Nothing in IDEA shall be construed to restrict” the ability to seek “remedies” under other Federal laws protecting the rights of children with disabilities. Before filing a civil action under other federal laws seeking relief that is also available under IDEA, the procedures under [§1415](f) and (g) shall be exhausted". 20 U.S.C. §1415(l).

After being informed that Petitioner, a deaf student, would not be graduating, Petitioner filed an administrative action against Respondents alleging that the school had failed to give Petitioner a "proper education," necessary under the Individuals with Disabilities Education Act (IDEA). The case was settled prior to the administrative hearing but Petitioner subsequently brought an action under the ADA seeking compensatory damages. The district court dismissed the claim, finding under 20 U.S.C. §1415(l), Petitioner was barred from bringing the ADA claim because he did not first exhaust IDEA’s administrative procedures. The Sixth Circuit affirmed. On appeal, the Supreme Court reversed, holding that Petitioner was not precluded from bringing the ADA claim as IDEA cannot provide compensatory damages that Petitioner sought to recover. The Court reasoned that based on the statutes terms and the interpretation that the term remedies is synonymous with relief a plaintiff seeks, there is no bar that a non-IDEA plaintiff sues for a remedy that’s unavailable under IDEA. Since the Petitioner is seeking compensatory damages that is not a remedy that is included under IDEA, the court determined that the Petitioner is not barred by that provision. Therefore, Petitioner is able to bring an action under ADA for compensatory damages without having to exhaust IDEA administrative procedures first.