Court Unanimously Holds That IDEA Administrative Remedy Requirements Do Not Preclude Compensatory Damages Under ADA: SCOTUS Today

While the backlog of argued cases pending decision has been growing substantially, the Court rendered only one opinion today, and it was unanimous.

In Perez v. Sturgis Public Schools, Justice Gorsuch wrote for the Court, reversing the Sixth Circuit and interpreting the administrative requirements of the Individuals with Disabilities Education Act (IDEA), 84 Stat. 175, as amended, 20 U. S. C. §§1400 et seq.

The case began when Perez, a deaf student, sued a Michigan school district that, over a period of years, had failed to provide him with a qualified sign language interpreter and had otherwise acted inappropriately with respect to his educational progress.

Justice Gorsuch noted that the statute was intended to ensure that children with disabilities receive a free and appropriate public education. Accordingly, the law sets forth various administrative dispute-resolution procedures that are to be followed by children, parents, teachers, and school districts.

The question before the Court was whether and, if so, to what extent, must children with disabilities exhaust the IDEA administrative remedies before seeking relief under other federal anti-discrimination statutes such as the Americans with Disabilities Act (ADA).

Perez's original suit had been settled favorably to him, with the school district agreeing to provide substantial prospective relief. After that settlement, Perez filed a lawsuit in federal district court under the ADA seeking backward-looking relief in the form of compensatory damages. The school system moved to dismiss on grounds including that Perez had failed to exhaust IDEA's administrative remedies.

Focusing on IDEA's terms that “[n]othing in [IDEA] shall be construed to restrict” the ability of individuals to seek “remedies” under the ADA or “other Federal laws protecting the rights of children with disabilities," but that “except that before the filing of a civil action under such [other federal] laws seeking relief that is also available under this subchapter, certain IDEA procedures must be followed,” Justice Gorsuch noted that the exhaustion requirements apply only to suits that “see[k] relief . . . also available under” IDEA. That precondition clearly does not apply where, as is the case with Perez, a disabled child brings a suit under another federal law for compensatory damages—a form of relief that everyone conceded IDEA does not provide. 

While this case is a matter of particular importance to the disability rights community, the unanimity of the decision shows, once again, that liberal and conservative Justices can find easy agreement on matters of clear textual language, and as a result, as I've suggested in earlier posts, increasingly the Court as a whole is focusing on textual solutions rather than on more divisive policy arguments.