In Perez v. Sturgis Public Schools, a student with disabilities sued her school district under the Americans with Disabilities Act (ADA) for denying her equal access to school programs and services. The school district argued that the student was required to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA) before pursuing monetary damages under the ADA for the same set of facts. The IDEA provides a dispute resolution process for parents and schools to resolve disputes over the provision of special education services, but it does not provide for monetary damages.
The U.S. Supreme Court unanimously held that exhaustion of administrative remedies under the IDEA is not a prerequisite to bringing an ADA claim for damages, even if the same facts underlie both claims. The Court held that IDEA and the ADA serve distinct purposes and provide separate remedies for different types of discrimination against individuals with disabilities. The IDEA focuses on ensuring that students with disabilities receive a free, appropriate public education, while the ADA prohibits discrimination against individuals with disabilities in all aspects of life, including education.
The Court’s decision clarifies that students with disabilities can pursue ADA claims for monetary damages without first exhausting administrative remedies under the IDEA. This decision reinforces the importance of the ADA in protecting the rights of individuals with disabilities and removing barriers to equal access in education and other areas of life. It also underscores the need for schools to ensure that students with disabilities have equal access to educational programs and services, and to address any discrimination or barriers that may exist.
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