Perez v. Sturgis Public Schools (2023)

By Lauren Fantroy-Winston

Overview

In Luna Perez v. Sturgis Public Schools, the Supreme Court addressed whether a student with disabilities must complete administrative procedures under the Individuals with Disabilities Education Act (IDEA) before filing a lawsuit under the Americans with Disabilities Act (ADA). The Court examined if Perez, who sought compensatory damages not available under IDEA, was still required to exhaust IDEA procedures.

Summary

Miguel Luna Perez attended school in Michigan’s Sturgis Public Schools district from ages 9 to 20, during which he received limited and inadequate support for his deafness. According to Perez and his family, the school repeatedly failed to meet his needs, including assigning aides unqualified to interpret or frequently absent. This left Perez without meaningful access to education, despite assurances from Sturgis that he was on track to graduate. Just months before graduation, the family learned that Perez would not receive a diploma, as he had not achieved the necessary academic milestones.

Following this revelation, Perez’s family filed a complaint under IDEA, which mandates that schools provide a “free appropriate public education” to students with disabilities. They alleged that Sturgis failed in this duty by not ensuring a qualified interpreter and by misrepresenting Perez’s progress. The two parties eventually reached a settlement under IDEA, in which Sturgis agreed to provide forward-looking relief, including additional schooling for Perez at a specialized institution. However, Perez sought further relief for the emotional and educational setbacks he experienced by filing a lawsuit under the ADA, where he sought compensatory damages for past harm, a remedy not available under IDEA. Sturgis moved to dismiss the case, arguing that Perez was required to exhaust all IDEA processes, which would bar his ADA claim. The lower courts upheld this interpretation, concluding that IDEA's exhaustion rule applied.

On appeal, the Supreme Court examined whether IDEA’s procedural requirements should extend to cases where plaintiffs are seeking forms of relief IDEA does not offer, like compensatory damages. Writing for a unanimous Court, Justice Gorsuch explained that IDEA’s requirement to exhaust administrative remedies only applies when plaintiffs pursue remedies that are available under IDEA. Since Perez’s lawsuit sought compensatory damages—an ADA remedy that IDEA cannot provide—the Court held that he was not required to complete IDEA’s procedures before moving forward with his ADA claim.

Impact

The U.S. Supreme Court ruled that if parents place their child in a private school due to an insufficient IEP, they may be entitled to reimbursement from the public school if the court later determines that the IEP was inadequate under the IDEA. While courts should give some deference to the decisions made by administrative hearing officers, they also retain the authority to independently evaluate the suitability of an IEP and the child’s placement.

The Court further held that parents do not lose their right to reimbursement by moving their child to a private school while disputes over the IEP are ongoing, ensuring they are not forced to keep their child in an inappropriate educational setting during legal proceedings.

In summary, the decision in Town of Burlington v. Department of Education for the Commonwealth of Massachusetts enhanced the procedural protections for parents and students under the IDEA. It allowed parents to seek appropriate placements without financial risk and clarified the level of judicial authority in granting remedies under the IDEA Act.

Court Documents:

To read more about Luna Perez v. Sturgis Public Schools click here: https://www.supremecourt.gov/opinions/22pdf/21-887_k53m.pdf