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Perez v. Sturgis Public Schools
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| Perez v. Sturgis Public Schools | |
| Term: 2022 | |
| Important Dates | |
| Argued: January 18, 2023 Decided: March 21, 2023 | |
| Outcome | |
| United States Court of Appeals for the Sixth Circuit reversed and remanded | |
| Vote | |
| 9-0 | |
| Majority | |
| Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson | |
Perez v. Sturgis Public Schools is a Supreme Court of the United States case decided on March 21, 2023, during the court's October 2022-2023 term, in which the court unanimously found that students with special needs and their families who seek relief for educational complaints are not required to exhaust the administrative adjudication procedures under the Individuals with Disabilities Education Act (IDEA) in all circumstances. The court held that students and families can seek relief in the courts under other federal statutes, such as the Americans with Disabilities Act (ADA), when the relief they seek is not addressed by IDEA.[1]
The case came on a writ of certiorari to the United States Court of Appeals for the Sixth Circuit. To review the lower court's opinion, click here.
Why it matters: The case clarified the extent to which a student must exhaust the administrative requirements under IDEA before seeking relief under another federal statute, such as the ADA. Justice Neil Gorsuch, writing for the court, found that "because IDEA does not provide compensatory damages, §1415(l) does not foreclose his ADA claim."[1]
Timeline
The following timeline details key events in this case:
- March 21, 2022: The U.S. Supreme Court reversed the decision from the Sixth Circuit and remanded the case for further proceedings.
- January 18, 2023: The U.S. Supreme Court heard oral argument.
- October 3, 2022: The U.S. Supreme Court agreed to hear the case.
- December 13, 2021: The petitioner appealed to the U.S. Supreme Court.
- June 25, 2021: The United States Court of Appeals for the Sixth Circuit affirmed the district court's ruling to dismiss the case.
Background
Miguel Perez, a 23-year-old deaf student who attended the Sturgis Public School District in Michigan, was assigned classroom aides throughout his schooling who were unqualified to work with deaf students. Despite advancing Perez through the grade levels, the school later informed the Perez family that Miguel would not graduate. The family filed a complaint with the Michigan Department of Education and argued that the school denied Miguel an adequate education and violated numerous federal and state education laws, such as the Individuals with Disabilities Education Act (IDEA), the Americans with Disabilities Act (ADA), and two Michigan disabilities laws.
The Sturgis Public School District and the Perez family settled the dispute over the Individuals with Disabilities Education Act (IDEA) before an administrative hearing took place and the school district agreed to provide forward-looking equitable relief and pay for Miguel to attend the Michigan School for the Deaf. The Perez family later sued the school district in the United States District Court for the Western District of Michigan for backward-looking relief through compensatory damages, arguing that the school discriminated against Miguel in violation of the Americans with Disabilities Act (ADA). The district court dismissed the Perez family’s claims and argued that they had to first exhaust all of the administrative remedies under IDEA before filing suit in the district court under the ADA. The Perez family then appealed to the United States Court of Appeals for the Sixth Circuit, which affirmed the judgment of the district court.[3]
Questions presented
The petitioner presented the following questions to the court:[2]
Questions presented:
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Oral argument
The U.S. Supreme Court heard oral argument on January 18, 2023.
Audio
Audio of oral argument:[5]
Transcript
Transcript of oral argument:[6]
Outcome
The court unanimously ruled that the administrative exhaustion requirements under the IDEA did not foreclose Perez's separate challenge seeking compensatory relief under the ADA since the IDEA does not address compensatory claims.
Justice Neil Gorsuch delivered the opinion of the court.
Opinion
Opinion of the court
Writing for the court, Justice Neil Gorsuch argued that the school district's reading of the IDEA was flawed. The district had claimed that Perez must first exhaust all IDEA administrative requirements before filing suit for compensatory damages under the ADA because his case was premised on the denial of a free and appropriate education. Gorsuch, however, argued that the IDEA does not address compensatory claims and, therefore, could not provide the relief sought by Perez:[1]
| “ | The second clause [of IDEA] bars individuals from 'seeking relief' under other federal laws unless they first exhaust 'the procedures under subsections (f) and (g).' But, by its terms, this limiting language does not apply to all suits seeking relief that other federal laws provide. The statute’s administrative exhaustion requirement applies only to suits that 'see[k] relief . . . also available under' IDEA. And that condition simply is not met in situations like ours, where a plaintiff brings a suit under another federal law for compensatory damages—a form of relief everyone agrees IDEA does not provide.[4] | ” |
Gorsuch further argued that IDEA did not demonstrate congressional intent to route educational complaints through administrative adjudication rather than the federal courts:[1]
| “ | The school district worries that our understanding of §1415(l) would frustrate Congress’s wish to route claims about educational services to administrative agencies with 'special expertise' in such matters. But 'it is .... our job to apply faithfully the law Congress has written,' and '[w]e cannot replace the actual text with speculation as to Congress’ intent.'[4] | ” |
Text of the opinion
Read the full opinion here.
October term 2022-2023
The Supreme Court began hearing cases for the term on October 3, 2022. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[7]
See also
External links
- Search Google News for this topic
- U.S. Supreme Court docket file - Perez v. Sturgis Public Schools (petitions, motions, briefs, opinions, and attorneys)
- SCOTUSblog case file for Perez v. Sturgis Public Schools
Footnotes
- ↑ 1.0 1.1 1.2 1.3 United States Supreme Court, "Perez v. Sturgis Publis Schools," March 24, 2023
- ↑ 2.0 2.1 U.S. Supreme Court, "QP REPORT 21-887 PEREZ V. STURGIS PUBLIC SCHOOLS," October 3, 2022
- ↑ Google Scholar, Perez v. Sturgis Public Schools, accessed February 10, 2023
- ↑ 4.0 4.1 4.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ [Oral argument audio page https://www.supremecourt.gov/oral_arguments/audio/2022/21-887 Supreme Court of the United States, "Oral Argument - Audio," argued January 18, 2023]
- ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued January 18, 2023
- ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
