FRY v. Napoleon Community Schools
U.S. Supreme Court · decided February 22, 2017 · Supreme Court Database (Spaeth)
- Decided
- February 22, 2017
- Term
- October Term 2016
- Vote
- 8–0
- Majority author
- Justice Kagan
- Issue area
- Civil Rights
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice KAGAN delivered the opinion of the Court. 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 clear that nothing in the IDEA "restrict[s] or limit[s] the rights [or] remedies" that other federal laws, including antidiscrimination statutes, confer on children with disabilities. At the same time, the section states that if a suit brought under such a law "seek[s] relief that is also available under" the IDEA, the plaintiff must first exhaust the IDEA's administrative procedures. In this case, we consider the scope of that exhaustion requirement. We hold that exhaustion is not necessary when the gravamen of the plaintiff's suit is something other than the denial of the IDEA's core guarantee-what the Act calls a "free appropriate public education." § 1412(a)(1)(A). I A The IDEA offers federal funds to States in exchange for a commitment: to furnish a "free appropriate public education"-more concisely known as a FAPE-to all children with certain physical or intellectual disabilities. Ibid. ; see § 1401(3)(A)(i) (listing covered disabilities). As defined in the Act, a FAPE comprises "special…
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