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Supreme Court Rules for Deaf Student Denied Appropriate Education

By Nicole Ezeh  |  May 3, 2023

A U.S. Supreme Court ruling in a case involving a deaf student changes the legal playing field for many school districts and state boards of education by making them open to both administrative proceedings and civil suits over inadequate resources for disabled students.

Students with disabilities have the same right as all other students to K-12 public education, including one that is free and appropriately designed to meet individual educational needs. These rights are enshrined in several laws, including the Individuals with Disabilities Educational Act (IDEA) and the Americans with Disabilities Act (ADA). Both statutes confer a right to seek either equitable relief or compensatory (monetary) relief when a disabled child’s educational rights are violated.

The case, Luna Perez v. Sturgis Public Schools, turns on whether the IDEA requires exhausting all possible administrative proceedings before seeking relief under the ADA.

The justices said Luna Perez could pursue his Americans with Disabilities Act claim because it sought relief not available to him via the Individuals with Disabilities Educational Act.

Miguel Luna Perez, who is deaf, attended school in Michigan’s Sturgis County School District from ages 9 through 20. Throughout his schooling in Sturgis, the district provided him with sign language interpreters to aid in translating classroom instruction. Luna Perez alleged that the aides the school provided were vastly underqualified—some did not know sign language—and often absent for hours at a time during the school day. Despite this, schools passed Luna Perez each year, giving him inflated grades and leading him to believe that he was on track to graduate from high school with his class. A few months before graduation, however, the school district told Luna Perez and his parents he would not graduate.

Luna Perez filed an administrative complaint against Sturgis under the IDEA, which mandates school districts provide audiology services to deaf students, including sign language interpreting and transliteration services. Luna Perez and Sturgis settled this complaint, with Sturgis providing Luna Perez relief in the form of educational services he needed and additional schooling at the Michigan School for the Deaf.

After the administrative settlement was completed, Luna Perez filed suit against Sturgis under the ADA, seeking compensatory damages for the years of inadequate accommodations that prevented him from receiving an appropriate public education. In district court, Sturgis moved to dismiss the case, arguing that under Section 1415 of the IDEA, Luna Perez was barred from bringing an ADA claim until he exhausted all administrative dispute resolution procedures the IDEA offers.

Section 1415 states that, while the IDEA does not restrict the ability to seek remedies under other federal laws protecting the rights of children with disabilities, a person must exhaust the administrative procedures laid out by the IDEA before filing a civil action seeking relief that is also available under the statute. Sturgis argued that Luna Perez’s ADA case seeks relief for the same underlying harm the IDEA exists to address, and thus was barred because Luna Perez had exhausted all administrative procedures. Luna Perez argued that the IDEA does not provide compensatory damages, and attempting to complete the administrative process would be futile. The district court ruled in favor of Sturgis, and the 6th Circuit U.S. Court of Appeals agreed.

The Supreme Court reversed and unanimously ruled in favor of Luna Perez, reasoning that the IDEA does not provide the same remedies as the ADA. The IDEA can provide only equitable, not monetary, relief by compelling the defendant to perform or refrain from performing a certain act. Due to the administrative complaint, Luna Perez received equitable relief in the form of better educational services and additional schooling after the settlement. His later ADA action sought compensatory damages for the time prior to settlement when he was denied equal educational opportunity through appropriate accommodations.

Luna Perez’s claim would not be barred under the IDEA, the court said, because his ADA action was seeking relief that was not available under the IDEA. The court remanded the case for further proceedings.

Austin Reid is a senior legislative director in NCSL’s State-Federal Relations Program.

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