__ U.S. __ (2017), 15-497, Fry v. Napoleon Cmty. Sch.
|Citation:||__ U.S. __, 137 S.Ct. 743, 197 L.Ed.2d 46, 26 Fla.L.Weekly Fed. S 429, 85 U.S.L.W. 4053|
|Opinion Judge:||Kagan, Justice|
|Party Name:||STACY FRY, et vir, as Next Friends of Minor E. F., Petitioners v. NAPOLEON COMMUNITY SCHOOLS, et al|
|Attorney:||Samuel R. Bagenstos argued the cause for petitioners. Roman Martinez argued the cause for the United States, as amicus curiae. by special leave of court. Neal K. Katyal argued the cause for respondents.|
|Judge Panel:||Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Breyer, and Sotomayor, JJ., joined. Alito, J., filed an opinion concurring in part and concurring in the judgment, in which Thomas, J., joined. Justice Alito,|
|Case Date:||February 22, 2017|
|Court:||United States Supreme Court|
The Individuals with Disabilities Education Act (IDEA) provides federal funds to states for furnishing a “free appropriate public education” (FAPE) to children with disabilities, 20 U.S.C. 1412(a)(1)(A), and establishes administrative procedures for resolving disputes concerning the provision of a FAPE. The Americans with Disabilities Act (ADA) and the Rehabilitation Act also protect the rights of disabled children;... (see full summary)
Argued October 31, 2016
[Copyrighted Material Omitted]
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT
The Individuals with Disabilities Education Act (IDEA) offers federal funds to States in exchange for a commitment to furnish a free appropriate public education (FAPE) to children with certain disabilities, 20 U.S.C. § 1412(a)(1)(A), and establishes formal administrative procedures [197 L.Ed.2d 52] for resolving disputes between parents and schools concerning the provision of a FAPE. Other federal statutes also protect the interests of children with disabilities, including Title II of the Americans with Disabilities Act (ADA) and § 504 of the Rehabilitation Act. In Smith v. Robinson, 468 U.S. 992, 104 S.Ct. 3457, 82 L.Ed.2d 746, this Court considered the interaction between those other laws and the IDEA, holding that the IDEA was the exclusive avenue through which a child with a disability could challenge the adequacy of his education. Id., at 1009, 104 S.Ct. 3457, 82 L.Ed.2d 746. Congress responded by passing the Handicapped Children's Protection Act of 1986, overturning Smith 's preclusion of non-IDEA claims and adding a carefully defined exhaustion provision. Under that provision, a plaintiff bringing suit under the ADA, the Rehabilitation Act, or similar laws seeking relief that is also available under [the IDEA] must first exhaust the IDEA's administrative procedures. § 1415( l
Petitioner E. F. is a child with a severe form of cerebral palsy; a trained service dog named Wonder assists her with various daily life activities. When E. F.'s parents, petitioners Stacy and Brent Fry, sought permission for Wonder to join E. F. in kindergarten, officials at Ezra Eby Elementary School refused. The officials reasoned that the human aide provided as part of E. F.'s individualized education program rendered the dog superfluous. In response, the Frys removed E. F. from Ezra Eby and began homeschooling her. They also filed a complaint with the Department of Education's Office for Civil Rights (OCR), claiming that the exclusion of E. F.'s service animal violated her rights under Title II and § 504. OCR agreed, and school officials invited E. F. to return to Ezra Eby with Wonder. But the Frys, concerned about resentment from school officials, instead enrolled E. F. in a different school that welcomed the service dog. The Frys then filed this suit in federal court against Ezra Eby's local and regional school districts and principal (collectively, the school districts), alleging that they violated Title II and § 504 and seeking declaratory and monetary relief. The District Court granted the school districts' motion to dismiss the suit, holding that § 1415( l ) required the Frys to first exhaust the IDEA's administrative procedures. The Sixth Circuit affirmed, reasoning that § 1415( l ) applies whenever a plaintiff's alleged harms are educational in nature.
1. Exhaustion of the IDEA's administrative procedures is unnecessary where the gravamen of the plaintiff's suit is something other than the denial of the IDEA's core guarantee of a FAPE. Pp. ___ - ___, 197 L.Ed.2d, at 58-64.
(a) The language of § 1415( l ) compels exhaustion when a plaintiff seeks relief that is available under the IDEA. Establishing the scope of § 1415( l ), then, requires identifying the circumstances in which the IDEA enables a person to obtain redress or access a benefit. That inquiry immediately reveals the primacy of a FAPE in the statutory scheme. The
IDEA's stated purpose and specific commands center on ensuring a FAPE for children with disabilities. And the IDEA's administrative procedures test whether a school has met this [197 L.Ed.2d 53] obligation: Any decision by a hearing officer on a request for substantive relief shall be based on a determination of whether the child received a free appropriate public education. § 1415(f)(3)(E)(i). Accordingly, § 1415( l )s exhaustion rule hinges on whether a lawsuit seeks relief for the denial of a FAPE. If a lawsuit charges such a denial, the plaintiff cannot escape § 1415( l ) merely by bringing the suit under a statute other than the IDEA. But if the remedy sought in a suit brought under a different statute is not for the denial of a FAPE, then exhaustion of the IDEA's procedures is not required. Pp. ___ - ___, 197 L.Ed.2d, at 58-61.
(b) In determining whether a plaintiff seeks relief for the denial of a FAPE, what matters is the gravamen of the plaintiff's complaint, setting aside any attempts at artful pleading. That inquiry makes central the plaintiff's own claims, as § 1415( l ) explicitly requires in asking whether a lawsuit in fact seeks relief available under the IDEA. But examination of a plaintiff's complaint should consider substance, not surface: § 1415( l ) requires exhaustion when the gravamen of a complaint seeks redress for a school's failure to provide a FAPE, even if not phrased or framed in precisely that way. In addressing whether a complaint fits that description, a court should attend to the diverse means and ends of the statutes covering persons with disabilities. The IDEA guarantees individually tailored educational services for children with disabilities, while Title II and § 504 promise nondiscriminatory access to public institutions for people with disabilities of all ages. That is not to deny some overlap in coverage: The same conduct might violate all three statutes. But still, these statutory differences mean that a complaint brought under Title II and § 504 might instead seek relief for simple discrimination, irrespective of the IDEA's FAPE obligation. One clue to the gravamen of a complaint can come from asking a pair of hypothetical questions. First, could the plaintiff have brought essentially the same claim if the alleged conduct had occurred at a public facility that was not a school? Second, could an adult at the school have pressed essentially the same grievance? When the answer to those questions is yes, a complaint that does not expressly allege the denial of a FAPE is also unlikely to be truly about that subject. But when the answer is no, then the complaint probably does concern a FAPE. A further sign of the gravamen of a suit can emerge from the history of the proceedings. Prior pursuit of the IDEA's administrative remedies may provide strong evidence that the substance of a plaintiff's claim concerns the denial of a FAPE, even if the complaint never explicitly uses that term. Pp. ___ - ___, 197 L.Ed.2d, at 61-64.
2. This case is remanded to the Court of Appeals for a proper analysis of whether the gravamen of E. F.'s complaint charges, and seeks relief for, the denial of a FAPE. The Frys' complaint alleges only disability-based discrimination, without making any reference to the adequacy of the special education services E. F.'s school provided. Instead, the Frys have maintained that the school districts infringed E. F.'s right to equal access--even if their actions complied in full with the IDEA's requirements. But the possibility remains that the history of these proceedings might [197 L.Ed.2d 54] suggest something different. The parties have not addressed whether the Frys initially pursued the IDEA's administrative remedies, and the record is cloudy as to the relevant facts. On remand, the court below should establish whether (or to what extent) the Frys invoked the IDEA's dispute
resolution process before filing suit. And if the Frys started down that road, the court should decide whether their actions reveal that the gravamen of their complaint is indeed the denial of a FAPE, thus necessitating further exhaustion. Pp. ___ - ___, 197 L.Ed.2d, at 64-65.
788 F.3d 622, vacated and remanded.
Samuel R. Bagenstos argued the cause for petitioners.
Roman Martinez argued the cause for the United States, as amicus curiae. by special leave of court.
Neal K. Katyal argued the cause for respondents.
Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Breyer, and Sotomayor, JJ., joined. Alito, J., filed an opinion concurring in part and concurring in the judgment, in which Thomas, J., joined.
The Individuals with Disabilities Education Act (IDEA or Act), 84 Stat. 175, as amended, 20 U.S.C. § 1400 et seq., ensures that children with disabilities receive needed special education services. One of its provisions, § 1415( l ), addresses the Act's relationship with other laws protecting those children. Section 1415( l ) makes...
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