Batchelor Ex Rel. R.B. v. Rose Tree Media School District
2014 U.S. App. LEXIS 13641
| 3rd Cir. | 2014Background
- Ryan Batchelor, diagnosed with ADHD (disability under §504) during 2008-09; District created a 504 Plan and then failed to implement for sophomore year due to scheduling and notice gaps.
- IEP process later led to an IEP and a settlement offering compensatory education hours in Sept. 2010, which was not fully reimbursed by the District.
- During junior year, additional alleged retaliation included tutoring changes, disciplinary actions, and perception of bullying, contributing to Ryan’s withdrawal and senior-year restrictions (choir/dance participation).
- Appellants sued alleging: (i) IDEA retaliation/FAPE violation; (ii) Section 504 retaliation; (iii) ADA retaliation; seeking damages, fees, and other relief.
- District Court dismissed for lack of subject-matter jurisdiction on grounds of failure to exhaust IDEA administrative remedies; Appellants appealed.
- Court determined IDEA exhaustion applies to Counts II–IV; retaliation claims relate to FAPE and thus must be exhausted; no applicable exceptions (monetary damages, implementation, futility) justified exhaustion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether IDEA exhaustion applies to all federal claims | Batchelor argued retaliation claims fall outside IDEA scope | District argued all claims are subject to IDEA exhaustion | Counts II–IV require IDEA exhaustion (no exemption) |
| Do retaliation claims under §504/ADA relate to FAPE and require exhaustion | Batchelor contends retaliation claims are independent of IDEA | District contends retaliation relates to FAPE and falls under IDEA scope | Retaliation claims relate to FAPE and are subject to IDEA exhaustion |
| Do any exceptions to IDEA exhaustion apply (monetary damages, implementation, futility) | Appellants seek monetary damages and argue futility/implementation | Exhaustion required; exceptions not met | No applicable exception; exhaustion required |
| Is the settlement/previous remedies a basis to avoid exhaustion | Settlement evidence shows prior relief; argues futility | Settlement not final due process decision; futility not established | Not a basis to foreclose exhaustion; matters ongoing |
| Did the district court have subject-matter jurisdiction to dismiss under Rule 12(b)(1) | Jurisdiction existed if exhaustion not required | Exhaustion absent; lack of jurisdiction | Correctly dismissed for lack of subject-matter jurisdiction due to failure to exhaust |
Key Cases Cited
- Komninos v. Upper Saddle River Bd. of Educ., 13 F.3d 775 (3d Cir. 1997) (exhaustion required; IDEA remedies available on review)
- Rose v. Yeaw, 214 F.3d 206 (1st Cir. 2000) (retaliation claims relate to provision of FAPE; exhaustion needed)
- M.T.V. v. DeKalb Cnty. Sch. Dist., 446 F.3d 1153 (11th Cir. 2006) (retaliation claims relate to IDEA and require exhaustion)
- Charlie F. v. Bd. of Educ. of Skokie Sch. Dist. 68, 98 F.3d 989 (7th Cir. 1996) (monetary damages do not avoid IDEA exhaustion; educational remedies prevail)
- Polera v. Bd. of Educ. of the Newburgh Enlarged City Sch. Dist., 288 F.3d 478 (2d Cir. 2002) (implementation exception considered but not applicable here)
- Forest Grove Sch. Dist. v. T.A., 557 U.S. 230 (2009) (remedies including private tutoring and reimbursement under IDEA)
- Chambers v. Sch. Dist. of Phila. Bd. of Educ., 587 F.3d 176 (3d Cir. 2009) (IDEA remedies may include attorneys’ fees and compensatory education)
- Ferren C. v. Sch. Dist. of Phila., 612 F.3d 712 (3d Cir. 2010) (compensatory education and remedies under IDEA)