## Facts

- Mrs. M. was the mother of I., a school-aged child in Bridgeport, Connecticut, eligible for special-education services under the Individuals with Disabilities Education Act (IDEA).
- The Bridgeport Board of Education classified I. as mentally disabled.
- Mrs. M. alleged the classification was wrong and discriminatory, and that minority students were being incorrectly identified as mentally disabled.
- Mrs. M. alleged the district maintained a policy or practice of misidentifying minority children as mentally disabled, resulting in improper special-education placement.
- Mrs. M. exhausted IDEA administrative procedures as to I.’s identification and placement but did not obtain relief.
- Mrs. M. filed a federal action on behalf of I. and sought to proceed on behalf of a class of similarly situated minority students who had not completed IDEA administrative procedures.
- The Board moved to dismiss the class-related claims for failure to exhaust administrative remedies.

## Issues

1. Whether IDEA-related class claims may proceed in federal court when putative class members did not exhaust IDEA administrative remedies.
2. Whether Connecticut’s available administrative remedies—including due-process procedures and the state complaint resolution procedure—must be used before bringing systemic IDEA claims.
3. Whether any exception to exhaustion (such as futility or inadequacy) excused exhaustion for the proposed class’s systemic misidentification allegations.

## Decision

- The court granted the Board’s motion to dismiss the class-action allegations.
- The court held that putative class members could not litigate IDEA-related claims in federal court without exhausting administrative remedies.
- The court treated the state’s written complaint resolution procedure, required by federal regulation, as an available administrative remedy for alleged systemic IDEA violations.
- The court rejected reliance on exhaustion by Mrs. M. for her child as a substitute for exhaustion by other children with distinct claims.
- The court found no applicable exception that would excuse exhaustion for the class-wide allegations.

## Legal Principles

- IDEA plaintiffs generally must exhaust available administrative remedies before filing suit in federal court, absent a recognized exception.
- Exhaustion serves to develop a factual record, apply educational agency expertise, and allow the agency an initial opportunity to correct alleged violations.
- A state complaint resolution procedure required by 34 C.F.R. § 76.780 can constitute an administrative remedy that must be pursued, including for allegations of district-wide or policy-based IDEA violations.
- Class allegations do not avoid exhaustion requirements where putative class members have not used the administrative process and no exception applies.

## Conclusion

The court dismissed the proposed IDEA class allegations because the other students had not exhausted available administrative remedies, including the state complaint resolution procedure, and no exception justified bypassing the administrative process.


Mrs. M. v. Bridgeport Bd. of Educ., 96 F. Supp. 2d 124 (D. Conn. 2000)