Perez v. Sturgis Public Schools

Miguel Luna Perez, a deaf student in Sturgis, Michigan, alleged that his school district failed for years to provide qualified sign language interpreters, instead assigning aides who were not fluent in American Sign Language. His family filed an administrative complaint under the Individuals with Disabilities Education Act (IDEA) and later settled with the district for forward-looking educational relief. Perez then sued in federal court under the Americans with Disabilities Act (ADA), seeking compensatory damages for the denial of a free appropriate public education. The school district argued that IDEA's exhaustion requirement barred the lawsuit because Perez had not completed all administrative appeals. The U.S. Supreme Court unanimously rejected that argument, holding that exhaustion applies only to claims seeking relief available under IDEA. Since IDEA cannot award monetary damages, Perez could pursue ADA damages without further administrative exhaustion.

The U.S. Supreme Court unanimously reversed the Sixth Circuit in an opinion by Justice Neil Gorsuch, holding that IDEA exhaustion is not required for ADA claims seeking compensatory damages because such relief is not available under IDEA.

Whether IDEA's administrative exhaustion requirement precludes a student from pursuing non-IDEA claims for monetary damages, such as under the ADA, when those damages are not available through IDEA proceedings.

The ruling clarifies that students with disabilities can seek monetary damages under other federal laws even after settling IDEA claims. It strengthens accountability for school districts and expands access to legal remedies for discrimination in special education, preventing schools from using IDEA's administrative process to shield themselves from damages liability.