Padilla v. School District No. 1

Shayne Padilla (plaintiff) was a physically and developmentally disabled student in Denver School District No. 1 (district) (defendant). Padilla requested an administrative hearing to address an alleged failure by the district to follow her individualized education program (IEP). Padilla claimed that for five years, the district failed to provide specific services listed in her IEP and that district personnel repeatedly restrained her in a stroller and placed her in a windowless closet without supervision. One such incident led to Padilla tipping over and hitting her head, which caused a skull fracture and worsened a seizure disorder. Padilla claimed that the district also failed to provide sufficient homebound schooling for her when she had to miss school due to her injuries. At the time of Padilla’s hearing request, Padilla had moved to a new school district, and because she was no longer a resident of the district, the hearing officer denied Padilla’s request. Padilla brought two claims against the district in federal court. Padilla claimed that the district discriminated against her under the Americans with Disabilities Act (ADA). Padilla also brought claims under 42 U.S.C. § 1983, arguing that the district denied her a free appropriate public education in violation of the Individuals with Disabilities Education Act (IDEA). The district moved to dismiss the ADA and § 1983 claims, but the trial court denied the motion. The district appealed to the Tenth Circuit. The appellate court affirmed the trial court’s judgment as to the ADA claims, finding that Padilla did not need to exhaust her administrative remedies under the IDEA before bringing the ADA claims because Padilla’s ADA claims sought relief that was not available under the IDEA. The court then addressed the § 1983 claims.