Supreme Court rules for disabled student who wants damages under Americans with Disabilities Act

The Supreme Court has ruled that a federal student disability statute does not require aggrieved students to administratively exhaust their claims before filing suit in federal court, but only in certain circumstances unique to this case.

The case is Perez v. Sturgis Public Schools, issued on March 21. The Individuals with Disabilities Education Act (IDEA) is a comprehensive statute that allows disabled public school students to enjoy an appropriate education. It requires the school districts to devise an individualized education plan for the disabled student, and if the parents and school district disagree about the plan, they can litigate this dispute at an evidentiary hearing. Normally, the losing party has to appeal to a state education official to change the result before they can litigate the case in federal court. 

My experience in this area is that federal courts are loathe to find exceptions to the administrative exhaustion rule. This frustrates the parents of disabled students who want to bring suit in court rather than wait for the state education official to rule on any objections. But this case is different. 

The student in this case is hearing-impaired. His parents allege that the district's efforts to help their son were ineffective. The parties settled that dispute after the parents filed a complaint with the Michigan Department of Education. After that dispute settled, the family brought suit in federal court under the Americans with Disabilities Act, seeking damages for the civil rights violation that their son experienced. The district moved to dismiss that lawsuit, claiming the parents did not first file an administrative complaint with the state. This is the administrative exhaustion argument. The district court and Court of Appeals agreed with the district and the case was dismissed. The Supreme Court unanimously reverses and the case returns to the docket.

The plaintiffs in this case can sue directly in court for damages under the ADA, the Court says, because the IDEA does not provide for these damages for pain and suffering. If the IDEA does not provide for that remedy, then exhausting administrative remedies through the state educational system is pointless. The Supreme Court provides some statutory analysis to arrive at this result, demonstrating once again that statutes need to be carefully analyzed with an eye toward context before we can know what Congress intended when the statute was enacted. Not to bore you, but this analysis has to do with interpreting the words "remedies" and "relief" under the IDEA.