## Facts

- Kristopher Sellers, a public-school student, was not identified as learning disabled and emotionally disturbed for years and received no special education services until the 1995–1996 school year.
- His parents alleged the school system should have tested and evaluated him earlier based on academic indicators.
- The parties settled the educational-services issues through IDEA administrative proceedings.
- The parents pursued compensatory and punitive damages for alleged past violations under the IDEA, § 504 of the Rehabilitation Act, 42 U.S.C. § 1983, and Virginia law.
- IDEA hearing and review officers concluded they lacked authority to award compensatory or punitive damages.
- The district court dismissed the complaint under Rule 12(b)(6), concluding damages were unavailable under IDEA, the § 504 claim was inadequately pled, and the § 1983 claim failed with the federal statutory claims.

## Issues

1. Whether the IDEA authorizes compensatory and punitive damages for past failures to identify and serve a student with disabilities.
2. Whether the complaint stated a claim under § 504 of the Rehabilitation Act distinct from an IDEA-based denial of appropriate educational services.
3. Whether 42 U.S.C. § 1983 may be used to obtain relief for alleged IDEA violations.

## Decision

- The Fourth Circuit affirmed dismissal of the complaint.
- The IDEA does not authorize compensatory or punitive damages.
- The complaint failed to plead a viable § 504 claim because it did not allege disability-based discrimination, as opposed to deficient special-education identification or services.
- § 1983 is not available to enforce IDEA rights, given the IDEA’s comprehensive remedial scheme.

## Legal Principles

- IDEA relief is limited to remedies consistent with its educational and equitable focus; general tort-style compensatory and punitive damages are not available absent clear statutory authorization.
- A § 504 education claim requires allegations that a qualified student was excluded from, denied benefits of, or subjected to discrimination in a federally funded program solely by reason of disability; restating an IDEA violation is insufficient.
- When Congress provides a detailed enforcement scheme for statutory rights (including administrative procedures and specified judicial remedies), that scheme may preclude a parallel § 1983 action to enforce the same rights.

## Conclusion

The court held that plaintiffs seeking redress for alleged IDEA failures cannot recover compensatory or punitive damages under the IDEA, cannot use § 1983 to expand IDEA remedies, and must plead facts showing disability-based discrimination to proceed under § 504.


Sellers v. Sch. Bd. of Manassas, Va., 141 F.3d 524 (4th Cir. 1998)