Christopher W. v. Portsmouth School Committee

Christopher W. (plaintiff) was a student who was entitled to special-education services from the Portsmouth School Committee (the district) (defendant) for his learning and behavioral disabilities. By the time Christopher was in high school, he was frequently absent from school. Because of these absences, the district took a number of actions against Christopher, including giving him failing grades, awarding him no academic credit for classes, and suspending him. Christopher filed an administrative appeal with the state’s department of education, alleging that these actions violated the Education for All Handicapped Children Act (EAHCA). The state ordered the district to investigate these claims and proceed appropriately within the requirements of federal and state laws. Over the next few years, the district initiated a variety of special-education procedures, plans, and different placements for Christopher, but his excessive absences continued. Christopher voluntarily left a number of the schools in which he was placed and eventually attempted to reenroll in the first high school he had attended in the district. The district refused to reenroll Christopher in that school. Christopher never filed any type of administrative appeal during these proceedings, except for his initial complaint. Instead, he filed a complaint in federal district court, alleging that the district had violated the EAHCA and asking for a range of injunctive relief. The district court held that it lacked jurisdiction to hear the case because Christopher had failed to first exhaust administrative remedies. Christopher appealed.