By: Derek Hawkins//March 1, 2017//
United States Supreme Court
Case Name: Fry v. Napoleon Community Schools, et al
Case No.: 15-497
Focus: Exhaustion of Administrative Remedies – IDEA
Exhaustion of the Individuals with Disabilities Education Act’s administrative procedures is unnecessary where the gravamen of the plaintiff’s suit is something other than the denial of the IDEA’s core guarantee of a free appropriate public education.
“The language of §1415(l) compels exhaustion when a plaintiff seeks “relief” that is “available” under the IDEA. Establishing the scope of §1415(l), then, requires identifying the circumstances in which the IDEA enables a person to obtain redress or access a benefit. That inquiry immediately reveals the primacy of a FAPE in the statutory scheme. The IDEA’s stated purpose and specific commands center on ensuring a FAPE for children with disabilities. And the IDEA’s administrative procedures test whether a school has met this obligation: Any decision by a hearing officer on a request for substantive relief “shall” be “based on a determination of whether the child received a free appropriate public education.” §1415(f)(3)(E)(i). Accordingly, §1415(l)’s exhaustion rule hinges on whether a lawsuit seeks relief for the denial of a FAPE. If a lawsuit charges such a denial, the plaintiff cannot escape §1415(l) merely by bringing the suit under a statute other than the IDEA. But if the remedy sought in a suit brought under a different statute is not for the denial of a FAPE, then exhaustion of the IDEA’s procedures is not required.”
Vacated and remanded
Concurring: Alito, Thomas