Fry v. Napoleon Community Schools

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Disability Law
  • Date Filed: February 22, 2017
  • Case #: No. 15–497
  • Judge(s)/Court Below: 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.
  • Full Text Opinion

The exhaustion clause of the Individuals with Disabilities Education Act (IDEA) only applies if the gravamen of the plaintiff’s complaint seeks relief under the IDEA.

Petitioner was a child with severe cerebral palsy, a movement disorder affecting coordination, who used a service dog to help her with daily tasks and balance. Petitioner’s school administrators prohibited the service dog from joining her in class due to Petitioner’s participation in the free appropriate public education program (“FAPE”), under the Individuals with Disabilities Education Act (“IDEA”). The school argued that it made sufficient accommodation for Petitioner’s disability, because the program provided her with one-on-one educational assistance. The school’s decision ultimately lead Petitioner’s parents to remove her from the school. Petitioner filed a complaint with the U.S. Department of Education’s Office for Civil Rights (the “OCR”), claiming discrimination pursuant to Title II of the Americans with Disabilities Act, and separately under § 504 of the Rehabilitation Act. After the OCR ruled in Petitioner’s favor, she filed discrimination claims in federal district court under the same federal statutes. The complaint was dismissed for failure to exhaust all administrative remedies pursuant to 20 U.S.C. §1415(l) of the IDEA, and the Sixth Circuit Court of Appeals subsequently affirmed the dismissal. On appeal, the U.S. Supreme Court vacated the Sixth Circuit’s decision, based on the statutory construction of the IDEA’s exhaustion clause. The Court held that the clause required exhaustion of the IDEA’s remedy procedures only if the claimant sought relief under the IDEA. The Court further explained that “a court should look to the substance, or gravamen, of the plaintiff ’s complaint” to determine if they sought relief under the IDEA. Because the Sixth Circuit’s analysis looked overly broad at whether Petitioner’s injury was related to education, the Court remanded the case to apply the gravamen standard. VACATED and REMANDED.

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