Luna Perez v. Sturgis Public Schools
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Luna Perez v. Sturgis Public Schools and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Luna Perez v. Sturgis Public Schools.
In Luna Perez v. Sturgis Public Schools, the Supreme Court addressed whether the Individuals with Disabilities Education Act (IDEA) exhaustion requirement barred an ADA lawsuit for compensatory damages. The Court found that because compensatory damages are not available under IDEA, the exhaustion requirement does not apply. This decision reversed the Sixth Circuit's ruling.
Holding
The single most important “bottom line” of what the Court decided in Luna Perez v. Sturgis Public Schools.
The Court held that IDEA's exhaustion requirement does not preclude Mr. Perez's ADA lawsuit for compensatory damages because such relief is not available under IDEA.
Constitutional Concepts
These are the Constitution-related themes that appear in Luna Perez v. Sturgis Public Schools. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Luna Perez v. Sturgis Public Schools
The case involves the exhaustion of administrative procedures under IDEA, which relates to whether fair procedures were provided.
Syllabus excerpt (verbatim)Before fling a civil action under other federal laws 'seeking relief that is also available' under IDEA, 'the procedures under [§ 1415](f ) and (g) shall be exhausted.'
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Why Remedies and Relief is relevant to Luna Perez v. Sturgis Public Schools
The central issue is whether the relief sought under ADA is also available under IDEA, which involves the scope of remedies.
Syllabus excerpt (verbatim)IDEA's exhaustion requirement does not preclude Mr. Perez's ADA lawsuit because the relief he seeks (i. e., compensatory damages) is not something IDEA can provide.
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Why Standing is relevant to Luna Perez v. Sturgis Public Schools
The case discusses the ability of Mr. Perez to bring a lawsuit under ADA without exhausting IDEA procedures, which implicates standing.
Syllabus excerpt (verbatim)Mr. Perez reads § 1415(l)'s 'seeking relief ' clause as applying only if he pursues remedies that are also available under IDEA.
Key Quotes
Short excerpts from the syllabus in Luna Perez v. Sturgis Public Schools that support the summary and concepts above.
IDEA's exhaustion requirement does not preclude Mr. Perez's ADA lawsuit because the relief he seeks (i.e., compensatory damages) is not something IDEA can provide.
Mr. Perez's reading better comports with the statute's terms.
Sturgis suggests this interpretation is foreclosed by Fry v. Napoleon Community Schools, 580 U. S. 154.
