Perez v. Sturgis Public Schools (21-887)
argument 21-887Perez v. Sturgis Public Schools
Supreme Court of the United States
1h 28m
7 speakers
8 chapters
transcribed 8 days ago
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Transcript generated automatically by AI and may contain errors.
What is the central dispute over IDEA and ADA exhaustion requirements in Perez v. Sturgis?
We'll hear argument this morning in case twenty one eight eight seven, Perez versus Sturgis Public Schools. Mr Martinez?
Mr Chief Justice, and may it please the court, for twelve years Sturgis neglected Miguel, denied him an education, and lied to his parents about the progress he was allegedly making in school. This shameful conduct permanently stunted Miguel's ability to communicate with the outside world. It also violated two federal statutes, the IDEA and the ADA, giving different remedies to victims of discrimination. Miguel responded by doing everything the IDEA wants him to do. He filed an IDEA agency claim. He followed the IDEA settlement procedures and he accepted a favorable settlement, giving him full IDEA relief, including an immediate FAPE. Sturgis wants you to hold that this settlement extinguishes Miguel's separate and distinct rights
to money damages under the ADA. You should reject that. I want to emphasize three points. First, the text only requires exhaustion if a non IDEA claim seeks relief that's actually available under the IDEA. Exhaustion isn't required in cases like this one seeking only money damages, a remedy the IDEA does not authorize. Second, Miguel's settlement fully exhausted the IDEA procedures. Further exhaustion is unnecessary and it's futile, because it would be pointless. Miguel has already received everything he's entitled to under the IDEA statute. And third, the net effect of Sturgis' arguments here is to defy the IDEA's clear purpose. That purpose is twofold. One, getting kids a fape as quickly as possible and two, preserving their legal rights under other statutes in the Constitution.
Sturgis puts these goals on a collision course with each other. In any given case, its rule will either disincentivize settlements and block immediate fate relief, or it will nullify rights under other statutes. That makes no sense. Congress didn't punish kids for saying yes to favorable IDEA settlements. One way or the other, this case should proceed. I welcome the Court's questions.
If the um this if the statute were written uh in a way that um you had a progression of remedies from administrative, from informal to formal, and it was about the very same thing. That is the uh education of uh petitioner. then why uh then wouldn't this be exhausted uh at at some level?
Your Honor, we have just to ste step back and sort of clarify, we have a number of different arguments. Well I I
guess the difference d the difficulty I'm having is I can't see where ADA fits in with IDEA. That seems to be an entirely different remedy and whether we when we have PLRA cases, et cetera, it's usually about the same thing.
A hundred percent, Your Honor. I think that's exactly the right way to think about the statute. And I think what Congress was trying to do here was essentially say, we want you to have rights under both statutes. We want you to be able to go into court if necessary and vindicate your separate rights to separate types of relief under both statutes. But In circumstances in certain circumstances we want you to go through the IDEA administrative procedures first. And the text of the statute says that if your ADA claim is only seeking things that you can't get under the IDEA. In the words of Frye, if the consequence of your ADA claim if you brought it in the IDA procedure would be that the IDA hearing officer would have to send you away empty-handed because that statute just does not provide you that type of relief, that type of relief is not available, then you do not have to exhaust.
I guess that's why I'm having trouble considering it exhaustion.
Right.
Because it seems to be uh normally you would think of exhaustion as being uh similar, the relief would be similar to the uh exhausted claims. Exactly. This seems to be an entirely different statute. So I don't understand even the use of the term exhaustion here.
I I think it's it's a it's a unique sort of a one of a kind statute. And I think that in this kind of circumstance, when you have a unique statute, two things.
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Chapters
8 chapters
1
What is the central dispute over IDEA and ADA exhaustion requirements in Perez v. Sturgis?
0:01–11:13
2
How does the petitioner argue that a settlement under the IDEA satisfies exhaustion for ADA claims?
11:13–22:13
3
Why does the respondent claim that accepting an IDEA settlement extinguishes ADA rights?
22:13–32:21
4
What is the Court’s question about whether exhaustion applies only when the same relief is available under IDEA?
32:21–41:34
5
How do the parties interpret the statutory term “relief” in §1415(l) and its impact on ADA claims?
41:34–54:23
6
What role does the futility exception play in the exhaustion analysis for non‑IDEA relief?
54:23–1:06:02
7
How might a plaintiff pursue ADA damages after an IDEA settlement without violating exhaustion?
1:06:02–1:18:52
8
What default rule do the parties propose for handling settlement and future ADA claims?
1:18:52–1:28:57