## Facts

- Miguel Luna Perez, a deaf student, attended Sturgis Public Schools in Michigan under an IDEA Individualized Education Program (IEP) requiring sign-language interpretation.
- Perez and his family alleged the district provided unqualified interpreters and misrepresented his academic progress, leading him to believe he was on track to graduate.
- Near the end of his schooling, the district stated he would not be permitted to graduate and would not receive a diploma.
- Perez filed an IDEA administrative complaint alleging denial of a free appropriate public education (FAPE).
- The parties settled before a due process hearing, providing prospective educational relief (including additional schooling and compensatory educational services).
- Perez later filed a federal ADA lawsuit seeking compensatory damages for past harm stemming from the alleged denial of a FAPE.

## Issues

1. Whether 20 U.S.C. § 1415(l) requires exhaustion of IDEA administrative procedures before filing an ADA action seeking compensatory damages for a denial of a FAPE when IDEA does not provide compensatory damages.

## Decision

- The Supreme Court unanimously reversed and remanded.
- Section 1415(l) requires exhaustion only for actions “seeking relief that is also available under” IDEA.
- Because IDEA does not provide compensatory damages, Perez’s ADA claim for compensatory damages was not subject to IDEA exhaustion.

## Legal Principles

- IDEA’s exhaustion requirement in 20 U.S.C. § 1415(l) turns on the relief sought, not merely whether the allegations involve a denial of a FAPE.
- Exhaustion is required only when a plaintiff brings a non-IDEA civil action seeking remedies that IDEA can provide through its administrative process.
- When the requested remedy (such as compensatory damages) is unavailable under IDEA, § 1415(l) does not bar proceeding directly in court under another federal disability-rights statute.

## Conclusion

The Court held that a student may pursue an ADA claim for compensatory damages based on an alleged denial of a FAPE without exhausting IDEA procedures, because compensatory damages are not available under IDEA.


Perez v. Sturgis Pub. Schs., 598 U.S. 142 (2023)