## Facts

- Shayne Padilla, a minor student with severe physical and developmental disabilities, was entitled to special education and related services under the Individuals with Disabilities Education Act (IDEA) pursuant to an individualized education program (IEP).
- Padilla alleged that for about five years the school district failed to provide services specified in her IEP.
- Padilla further alleged that school personnel repeatedly placed her in a windowless closet and restrained her in a stroller without supervision, contrary to her IEP.
- During one incident, Padilla tipped over, struck her head, and suffered serious injuries, including a skull fracture and worsening of a seizure disorder, causing substantial absence from school.
- Padilla alleged the district failed to provide adequate homebound instruction while she was out of school.
- Padilla moved to a different school district and then sought an IDEA administrative due process hearing concerning the prior district’s conduct.
- A state hearing officer declined to hear the complaint, concluding he lacked jurisdiction because Padilla no longer resided in the district.
- Padilla filed a federal action asserting (1) disability discrimination under the Americans with Disabilities Act (ADA) and (2) a 42 U.S.C. § 1983 claim seeking damages for denial of a free appropriate public education (FAPE) and related constitutional violations.
- Defendants moved to dismiss for failure to exhaust IDEA administrative remedies; the district court denied the motion and certified an interlocutory appeal on exhaustion issues.

## Issues

1. Whether IDEA’s exhaustion provision requires exhaustion before bringing ADA claims seeking compensatory damages and other relief not available through IDEA procedures.
2. Whether the IDEA’s remedial scheme precludes enforcement of IDEA-based rights through 42 U.S.C. § 1983.
3. Whether exhaustion is excused when the state IDEA administrative forum declines jurisdiction over the complaint, making further administrative proceedings futile or inadequate.

## Decision

- The court affirmed the district court’s refusal to dismiss the ADA claims for lack of IDEA exhaustion to the extent Padilla sought compensatory damages not available under IDEA.
- The court held that IDEA does not bar use of § 1983 to enforce rights secured by the IDEA, but IDEA exhaustion generally applies to § 1983 claims seeking relief also available under IDEA.
- The court concluded exhaustion was excused on futility/inadequacy grounds because the hearing officer had declined to hear Padilla’s complaint based solely on residency, leaving no meaningful administrative path.
- The court affirmed the denial of the motion to dismiss, allowing the ADA and § 1983 claims to proceed in federal court.

## Legal Principles

- Under 20 U.S.C. § 1415(l), a plaintiff must exhaust IDEA administrative procedures only when filing a civil action “seeking relief that is also available” under the IDEA.
- ADA claims seeking compensatory damages for past physical and emotional injuries are not subject to IDEA exhaustion when such damages are unavailable through IDEA administrative remedies.
- The IDEA does not provide an exclusive remedial scheme that forecloses § 1983; § 1983 remains available to enforce IDEA-secured rights.
- Even when § 1983 is available, § 1415(l) requires exhaustion if the plaintiff seeks relief that IDEA can provide (typically educational remedies).
- Exhaustion is not required where it would be futile or inadequate, including where the state administrative process refuses to adjudicate the complaint for jurisdictional reasons.

## Conclusion

The Tenth Circuit held that IDEA exhaustion is relief-specific and excused where the administrative forum will not hear the dispute: Padilla could pursue ADA damages without exhaustion, could use § 1983 to enforce IDEA rights, and was excused from further IDEA proceedings because the state hearing officer declined jurisdiction, making exhaustion futile or inadequate.


Padilla v. Sch. Dist. No. 1, 233 F.3d 1268 (10th Cir. 2000)