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In a unanimous decision this week, the Supreme Court addressed the interplay between two federal laws – the Americans with Disabilities Act, or ADA, and the Individuals with Disabilities Education Act, or IDEA. The question raised was whether a family may sue a school district for damages under the ADA before exhausting the administrative process required by the IDEA. The Court ruled that the family need not exhaust the requirements of the IDEA before filing a lawsuit for damages under the ADA.
The case, Perez v. Sturgis Public Schools, was brought by the family of a deaf Michigan student who sued his school district for damages over profound lapses in his education, alleging violations of state and federal laws, including the IDEA. Before the initial complaint was resolved, the school district agreed to pay for Perez to attend a private school, and the case was settled. The family then sued the school district under the ADA, seeking monetary damages. A federal district court dismissed the lawsuit because the IDEA requires that before filing a lawsuit under the ADA for relief also available through the IDEA, a party must exhaust the IDEA’s administrative process. By accepting the settlement before a hearing took place, the family had not exhausted the IDEA’s administrative process. A divided panel of the U.S. Court of Appeals for the 6th Circuit agreed.
The Supreme Court reversed, holding that the IDEA did not bar Perez from seeking damages under the ADA. The IDEA, according to the majority opinion, requires plaintiffs who sue under another federal law to exhaust its administrative process only when they are seeking a remedy that the IDEA also provides. Because Perez’s ADA lawsuit seeks monetary damages not provided for by the IDEA, it is not barred.
