Doe v. Belleville Public School District No. 118

Johnny Doe (plaintiff) was a six-year-old child diagnosed with hemophilia and Acquired Immune Deficiency Syndrome (AIDS). Doe was preparing to enroll as a first-grade student in Belleville Public School District No. 118 (district) (defendant). The district was notified of Doe’s conditions, and after analyzing his case, the district created a policy for children with communicable diseases that the district used to place Doe. The district did not follow state guidelines for placing children with contagious diseases, opting to create a new process. The newly created policy provided that an interdisciplinary committee would review Doe’s case and determine his school placement, and the decision could be appealed only to the district itself. The committee appointed by the district decided to exclude Doe from the normal classroom and instead provide him with a private tutor. Doe filed suit against the district in federal court, claiming that the district discriminated against him in violation of the Rehabilitation Act. The district filed a motion to dismiss and argued that Doe’s claim arose under the Education for All Handicapped Children Act (EHA), later renamed the Individuals with Disabilities Education Act. The district claimed that under the EHA, the court did not have subject-matter jurisdiction over the case because Doe had not exhausted his state-law administrative remedies before filing his claim. The court addressed whether Doe was considered disabled under the EHA and subject to the exhaustion requirement.