Perez v. Sturgis Public Schools

Miguel Perez (plaintiff) was deaf. He attended school in Michigan’s Sturgis Public School District (the school district) (defendant) from age nine to 20. While Perez was a student, the school district provided aides to translate classroom instruction into sign language. Perez claimed many of these aides were either unqualified or absent for extended periods. Perez also asserted that the school district inflated his grades and promoted him regardless of his academic progress. Perez and his parents mistakenly believed he was on schedule to graduate with his class. However, just months before graduation, the school district informed Perez he would not be receiving a diploma. Perez and his parents filed a complaint with the Michigan Department of Education, alleging that the school district had violated the federal Individuals with Disabilities Education Act (IDEA) by failing to provide him with an appropriate public education. This complaint sought only forward-looking relief, which was all the IDEA permitted. Before the IDEA administrative process was complete, Perez and the school district reached a settlement. In this settlement, the school district granted Perez his requested forward-looking relief, including additional schooling at the Michigan School for the Deaf. Perez then filed a civil complaint in federal district court. This complaint alleged the school district had violated the Americans with Disabilities Act (ADA) and sought only backward-looking, compensatory relief. The district court found this civil lawsuit was barred by an IDEA provision requiring exhaustion of all IDEA administrative procedures before an individual was allowed to file a civil lawsuit “seeking relief” that was “also available” under the IDEA. The United States Court of Appeals for the Sixth Circuit affirmed the dismissal of Perez’s civil ADA lawsuit. The United States Supreme Court granted certiorari.