Supreme Court Decides Perez v. Sturgis Public Schools
On March 21, 2023, the Supreme Court of the United States issued a unanimous ruling in Perez v. Sturgis Public Schools, No. 21–887. The opinion, delivered by Justice Gorsuch, determined that children with disabilities need not exhaust the administrative proceedings required by the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. §1400, et seq., before seeking additional remedies under the Americans with Disabilities Act (ADA), 42 U.S.C. §12101, et seq., or other comparable federal antidiscrimination statutes.
The allegations in the case state that, for years, the Sturgis Public School District in the State of Michigan (“Sturgis”) failed to provide appropriate educational assistance to a deaf student, Miguel Luna Perez. In addition, Sturgis also misrepresented Mr. Perez’s development to his parents, awarding him inflated grades and allowing him to advance grades regardless of his actual progress. When he was about to graduate high school, Sturgis notified his parents that he would not be able to graduate. Mr. Perez and his family filed an administrative complaint with the Michigan Department of Education, alleging violations of IDEA and other laws. Eventually, the parties reached a settlement agreement which provided “forward-looking equitable relief” that included additional schooling for Mr. Perez.
Mr. Perez then filed a federal lawsuit against Sturgis seeking “backward-looking relief”, in the form of compensatory damages under the provisions of ADA. In response, Sturgis argued that §1415(l) of IDEA barred Mr. Perez from bringing such ADA claims without first exhausting all of IDEA’s dispute resolution procedures. The District Court agreed and dismissed the complaint. The United States Court of Appeals for the Sixth Circuit then affirmed the District Court’s decision, bound by precedent addressing this question.
Both parties agreed that the “backward-looking” compensatory damages sought by Mr. Perez under his ADA claims were remedies which were not available under IDEA. Mr. Perez argued that the requirement to exhaust administrative processes was inapplicable to his case, since it only affects remedies that were also available under IDEA. Sturgis argued that Mr. Perez’s claims under ADA fall within the purview of IDEA, and were therefore prohibited because they sought relief for the same underlying harm related to his educational needs.
The opinion of the Court concluded that nothing in IDEA impedes Mr. Perez’s ADA lawsuit because the requirements of exhausting administrative proceedings cannot affect other additional remedies available under a different statute. If the lawsuit had requested both damages and the equitable relief provided by IDEA, the request for equitable relief would be barred, or deferred, pending exhaustion of the corresponding administrative proceedings. However, since Mr. Perez’s ADA lawsuit only sought compensatory damages that were unavailable under IDEA, the claims can proceed.
The opinion of the Court deals solely with the provision of IDEA and can have far reaching effects on the rights of students in a public education setting. Other questions raised by the parties were expressly not considered, such as whether the compensatory damages sought by Mr. Perez in his ADA suit are, in fact, available under that statute.