Unanimous Ruling by the U.S. Supreme Court in a Special Education Case

On March 21, 2023, the U.S. Supreme Court issued a unanimous ruling in Perez v. Sturgis Public Schools. In the 9-0 ruling, which was written by Associate Justice Neil Gorsuch, the High Court reversed and remanded the case to the U.S. Court of Appeals for the 6th Circuit for further proceedings based on the Supreme Court’s opinion. To read the decision, click here.

The case involved Miquel Perez, a deaf student, who filed a lawsuit under the Americans with Disabilities Act (ADA) against the Sturgis Public Schools in Michigan for failing to provide him with a qualified sign language interpreter. Miquel had filed a due process complaint against the Sturgis Public Schools but before the Michigan Department of Education could hold a hearing, the Sturgis school board settled Miquel’s claim.

The Perez’s then filed a lawsuit in federal court alleging that the Sturgis school district failed to provide Miquel with the resources he needed to fully participate in school, which violated the ADA. The federal district court dismissed Miquel’s claim finding that he could only file his lawsuit after exhausting administrative remedies under the Individuals with Disabilities Education Act (IDEA). Essentially, the district court dismissed the lawsuit because Miquel had accepted a settlement agreement rather than going through the IDEA’s administrative proceedings, which includes a due process hearing. The case was appealed to the U.S. Court of Appeals for the 6th Circuit, in which a divided panel upheld the ruling of the lower court.

In an 8-page opinion written by Associate Justice Gorsuch, the Supreme Court reversed the ruling of the 6h circuit court. Gorsuch wrote that the IDEA requires plaintiffs who file a lawsuit under another federal law to exhaust all administrative procedures outlined in the IDEA only when they are seeking a remedy that the IDEA also provides. Because the IDEA does not include monetary damages, Perez’s lawsuit seeking compensation for emotional distress and loss of income, was not subject to the IDEA’s administrative exhaustion rule. After the Supreme Court’s ruling, Miquel Perez will no doubt continue to pursue his legal claims under the ADA.

What might this case mean? Some school officials believe the ruling will result in increased litigation because it injects the possibility of monetary damages. Parent advocacy groups, on the other hand, believe that the ruling may make schools more likely to negotiate in good faith because they not be immunized from the threat of lawsuits seeking monetary damages. Only time will tell what this ruling means. It is very unlikely that teachers or administrators will see any changes on the ground resulting from this ruling.

USA Today published an excellent article summarizing the case that includes a picture of Miquel Perez (who is now 27 years old). You can read the USA Today article by clicking here.

You can hear the oral arguments in the case at Oyez.com and read about the case, including proceedings, orders, and friend of the court briefs at SCOTUSblog.

Categories: Uncategorized

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