A.Z. v. Santa Maria Joint Union High School District CA2/6, B306374

Plaintiff A.Z., injured in 2015 at age 15, sustained a traumatic brain injury (TBI) while a student in Santa Maria Joint Union High School District.
District identified A.Z. as disabled and issued Section 504 plans without conducting assessments; accommodations were alleged to be generic and inadequate for TBI-specific needs.
A neuropsychological evaluation two years after injury documented persistent TBI symptoms; A.Z. claims the District nonetheless failed to provide appropriate educational services, causing academic decline and lasting impairments.
A.Z. sued under 42 U.S.C. § 1983 alleging violations of the ADA and Rehabilitation Act and sought only monetary damages; she did not pursue IDEA administrative procedures or a due-process hearing.
The trial court sustained the District’s demurrer without leave to amend, holding A.Z. failed to exhaust IDEA administrative remedies under 20 U.S.C. § 1415(l).
The Court of Appeal affirmed, concluding the gravamen of A.Z.’s claim was denial of a free appropriate public education (FAPE) and exhaustion was required even though she sought monetary damages.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether IDEA exhaustion under 20 U.S.C. § 1415(l) is required where plaintiff seeks only monetary damages for harms caused by a school's alleged failure to provide appropriate educational services for a TBI	A.Z.: her claims are for personal, non‑educational injuries that monetary damages alone address; IDEA procedures cannot now help, so exhaustion would be futile and unnecessary	District: the complaint’s gravamen is denial of a FAPE; exhaustion is required under §1415(l) even if plaintiff seeks monetary relief unavailable under the IDEA	Court: exhaustion required. Because the claim seeks relief for denial of a FAPE, §1415(l) bars filing until IDEA administrative remedies are exhausted; artful pleading cannot avoid the requirement

Fry v. Napoleon Community Schools, 137 S. Ct. 743 (2017) (IDEA exhaustion required when lawsuit seeks relief that is also available under the IDEA; courts must assess the complaint’s gravamen)
Smith v. Robinson, 468 U.S. 992 (1984) (Section 504 interpreted to require recipients of federal funds to provide FAPE; later addressed by statute and Fry)
Mark H. v. Lemahieu, 513 F.3d 922 (9th Cir. 2008) (Section 504 requires free appropriate public education in K–12 settings)
Charlie F. by Neil F. v. Bd. of Educ. of Skokie Sch. Dist. 68, 98 F.3d 989 (7th Cir. 1996) (plaintiffs cannot evade IDEA exhaustion simply by seeking only monetary damages)
Padilla ex rel. Padilla v. Sch. Dist. No. 1, 233 F.3d 1268 (10th Cir. 2000) (focus on source and nature of alleged injuries in deciding whether IDEA remedies are available)
Nieves‑Marquez v. Puerto Rico, 353 F.3d 108 (1st Cir. 2003) (compensatory education remains a form of relief available under the IDEA)