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Fry v. Napoleon Community Schools

United States Supreme Court
137 S. Ct. 743 (2017)


The Individuals with Disabilities Education Act (IDEA) sought to guarantee “free appropriate public education” for children with disabilities. IDEA stated that if a claim under another federal antidiscrimination law could provide relief that was also available under IDEA, the claimant would need to exhaust his or her administrative remedies under IDEA prior to pursuing the other claim. E.F. was a child with cerebral palsy. E.F. had a trained service dog to help her with daily activities. E.F.’s kindergarten, Ezra Eby Elementary School (defendant), refused to let E.F. bring her service dog to school. Stacy and Brent Fry (plaintiffs) filed a complaint with the United States Department of Education’s Office of Civil Rights (OCR), alleging violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act. OCR found in favor of the Frys. The school appealed, arguing that the Frys had not exhausted their administrative remedies under IDEA. The court of appeals found that the Frys’ claims were educational in nature and thus had to be exhausted through IDEA’s administrative process prior to judicial review. The United States Supreme Court granted certiorari.

Rule of Law


Holding and Reasoning (Kagan, J.)

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