Supreme Court Ruling Could Impact Special Education Claims
In the wake of a recent Supreme Court decision, the attorneys at Murphy, Lamere & Murphy, P.C. are cautioning clients that the decision could impact the manner in which many special education claims are filed in Massachusetts.
On March 21, 2023, the United States Supreme Court issued its ruling in Perez v. Sturgis, 143 S. Ct. 859 (2023), determining that in some cases, plaintiffs do not have to exhaust their administrative remedies under the Individuals with Disabilities Education Act (IDEA) prior to seeking damages in court under other laws, such as the Americans with Disabilities Act (ADA) or other federal anti-discrimination laws. The case originated out of a special education appeal in Michigan in which a parent alleged the schools had failed to provide their child with a free appropriate public education as required by the IDEA because the child was provided with unqualified staff and the school misrepresented the child’s educational progress. The parent also filed suit in federal district court under the ADA alleging discrimination and seeking compensatory damages. The district court dismissed this claim, finding that the parent failed to first exhaust their administrative remedies under the IDEA before bringing the claim in court. The parent appealed.
The dispute on appeal revolved around 20 U.S.C. §1415(l), which provides that the IDEA should not be construed to restrict a plaintiff’s ability to seek remedies under other federal laws protecting the rights of children with disabilities, provided administrative procedures available under the IDEA must first be exhausted before a plaintiff can file a civil action “seeking relief that is also available” under the IDEA. This portion of the statute proved pivotal to the members of the Supreme Court, who ruled unanimously that because the statute only provides that exhaustion of administrative remedies is required for relief that is also available under the IDEA, the exhaustion requirement does not preclude the parent from immediately seeking relief in court for something IDEA cannot provide, such as compensatory damages under the ADA. As a result, the parent in this case could proceed in court with their claim for relief under the ADA regardless of any administrative appeal.
It is important to remember that the Court’s decision does not remove the requirement to exhaust administrative remedies for IDEA claims and, as a result, it is not likely to affect typical appeals or administrative procedures at state administrative agencies. However, the decision does increase the likelihood that some related claims may proceed immediately to court to the extent they raise issues beyond the scope of the IDEA. As a result, it will be important for school districts to remain in contact with their legal counsel in any special education appeals to be sure they understand the claims that are raised and the best practices for responding.
After the Court’s ruling, MLM issued an Info-Gram to school districts informing them of the Court’s ruling and recommending that in the event a complaint is filed against their school district, they should immediately contact their legal counsel to evaluate the claim and determine their next steps. Additional information regarding the decision and recommended next steps is available from the attorneys at MLM.
