No. 21-887, 598 U.S. ___ (2023).
March 21, 2023
Keywords: equitable relief, compensatory education, compensatory damages, Americans with Disabilities Act (ADA), Individuals with Disabilities Education Act (IDEA), disability, d/Deaf, special education, administrative procedures.
Miguel Luna Perez was a student in Michigan’s Sturgis Public School District. He received poor special education supports while in school. He settled claims under the Individuals with Disabilities Education Act (IDEA) for compensatory education. Compensatory education includes services that are needed to make up for skills or learning that has been lost when services described in an Individualized Education Program (IEP) were not provided.
Perez then filed a claim for compensatory (money) damages under the Americans with Disabilities Act (ADA).
The District Court dismissed his claim, saying he had not used all the administrative remedies found in the IDEA. The case was appealed to the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit agreed with the District Court decision.
The case was appealed to the United States Supreme Court. The Supreme Court ruled that the exception requiring the use of all administrative remedies under 20 U.S.C. § 1415(l) of the IDEA did not apply to claims for relief that were unavailable under the IDEA but available under other federal laws like the ADA, such as Perez’s claim for compensatory damages.
The decision was reversed, and the case was remanded (returned to the Sixth District Court of Appeals).
Facts of the Case
Miguel Luna Perez is a d/Deaf student who was enrolled in special education services provided by Michigan’s Sturgis Public School District (“Sturgis”) through age 20. Sturgis gave Mr. Perez sign language interpreters and other services to access and benefit from his education. Although Mr. Perez’s parents were regularly told that Mr. Perez was making adequate educational progress, Sturgis told the parents that Mr. Perez would not be allowed to graduate.
Mr. Perez’s parents filed an administrative complaint claiming that Sturgis failed to provide a free appropriate public education (FAPE) as required under the IDEA by providing unqualified sign language interpreters and lying about Mr. Perez’s progress. The administrative complaint was settled.
Mr. Perez’s parents then filed an ADA claim in federal district court for compensatory damages. Sturgis moved to dismiss based on a section in IDEA requiring families to use up all administrative procedures for civil actions seeking relief under the IDEA.
Issues of the Case
- Was Perez required to use all administrative procedures under the IDEA before seeking relief under the ADA?
Arguments & Analysis
1. Was Perez required to use all administrative procedures under the IDEA before seeking relief under the ADA?
The District Court agreed with Sturgis’ argument on a motion to dismiss believing Perez could not bring his ADA claim until he had used all administrative dispute resolution procedures found in the IDEA.
The Sixth Circuit Court of Appeals was restricted by previous circuit court rulings on the issue and upheld the lower court’s ruling.
The United States Supreme Court agreed to hear the case due to disagreement among the circuit courts. The Court first noted that 20 U.S.C. § 1415(l) has two features:
First, there is a general rule that allows individuals to make claims under other federal laws.
Second, there is an exception preventing civil actions under other federal laws when the relief is available under IDEA.
The Court addressed Sturgis’ argument that Perez had to use all administrative procedures under IDEA if the claim of underlying harm was the same in a suit filed under other federal laws. The Court discussed the plain language of the statute, including how the words “relief” and “remedy” are considered the same across several federal laws. The Court agreed with Perez that the underlying relief he asked for is based on whether administrative procedures under IDEA must be exhausted prior to pursuit of relief under another federal law.
In a rare unanimous decision the United States Supreme Court found that if the demand for relief in a non-IDEA claim cannot be provided under IDEA, then the IDEA does not prevent someone from seeking relief under other federal laws.
If the demand for relief is of a type that is available under the IDEA, then someone seeking relief cannot file under other federal laws until all administrative procedures have been exhausted under the IDEA.
In this case, because Perez was seeking compensatory damages under the ADA, something not allowed under the IDEA, his ADA claim was not blocked by the exhaustion exception in 20 U.S.C. § 1415(l).
Policy & Practice
If Perez’s ADA claim included a type of relief available under the IDEA, then he would have to exhaust the IDEA’s administrative procedures first.
- Full Case: Perez v. Sturgis Public Schools, No. 21-887, 598 U.S. ___ (2023) [PDF]
- Disability Rights Today! Podcast – Episode 8: Perez v Sturgis Public Schools
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These materials do not constitute legal advice and should not be relied upon in any individual case. Please consult an attorney licensed in your state for legal advice and/or representation. These materials were prepared by the legal research staff of the Burton Blatt Institute (BBI) at Syracuse University in partnership with the Southeast ADA Center to highlight legal and policy developments relevant to civil rights protections and the impact of court decisions in the Southeast Region under the Americans with Disabilities Act (ADA). These materials are based on federal disability rights laws and court decisions in effect at the time of publication. Federal and state disability rights law can change at any time. In addition, state and local laws and regulations may provide different or additional protections. Materials are intended solely as informal guidance, and are neither a determination of your legal rights nor responsibilities under the ADA or other federal, state, and local laws, nor binding on any agency with enforcement responsibility under the ADA. The accuracy of any information contained herein is not warranted. Any links to external websites are provided as a courtesy and are not intended to nor do they constitute an endorsement of the linked materials.