Crockett v. Mayor, Civil Action No. 2016-1357

Background

Crockett, a pro se plaintiff and former Wilson High School student, had an IEP under the IDEA; he alleges failures to implement accommodations, improper grade/attendance reporting, improper disclosures of education records, and other harms that caused him to miss graduating with his class.
Crockett previously pursued administrative remedies with OSSE and obtained a December 2014 ruling finding a denial of FAPE from Oct. 11, 2012 to Apr. 7, 2014, with compensatory relief awarded; he later brought a second OSSE due process hearing addressing math support and timely IEP notice, which resulted in limited relief.
In June 2015 Crockett sued in D.C. Superior Court seeking injunctive relief to participate in graduation; the Superior Court denied TRO/PI and dismissed the suit for failure to exhaust IDEA administrative remedies; the D.C. Court of Appeals later dismissed the appeal as moot.
Crockett filed this federal suit in June 2016 asserting ADA, IDEA, FERPA, DCHRA, D.C. Student Grievance, and multiple state-law tort claims (seeking damages only); some defendants overlapped with the Superior Court action, others were new; he mistakenly named DCPS and included the Mayor (he conceded the Mayor should not be a defendant).
Defendants moved to dismiss or for summary judgment, asserting claim and issue preclusion, failure to exhaust IDEA remedies, statute-of-limitations defenses to intentional torts, that DCPS is not sui juris, and lack of allegations against the Mayor.
The Court granted summary judgment on the IDEA claim (Count II) based on issue preclusion for failure-to-exhaust, substituted the District of Columbia for DCPS, dismissed claims against the Mayor, and otherwise denied defendants’ motions (without prejudice to renewing exhaustion-based defenses later as to related non-IDEA claims).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Superior Court dismissal bars relitigation (claim preclusion)	Crockett contends suit can proceed in federal court for damages after prior proceedings	Defendants argue prior Superior Court judgment is final on the merits and bars relitigation	Court: Claim preclusion does not apply because prior dismissal was for failure to exhaust (a precondition), not an adjudication on the merits
Whether Superior Court dismissal precludes relitigating exhaustion (issue preclusion)	Crockett did not satisfy exhaustion between cases	Defendants argue issue preclusion prevents relitigating IDEA exhaustion	Court: Issue preclusion applies to bar relitigation of whether Crockett exhausted IDEA remedies; grants summary judgment on IDEA claim (Count II)
Whether §1415(l)/Fry bars related non-IDEA claims (ADA, Rehab Act, state claims)	Crockett seeks damages under multiple statutes and torts	Defendants argue IDEA exhaustion can bar those claims as well	Court: Declines to resolve Fry/§1415(l) application here; denies motion as to non-IDEA claims without prejudice (defendants may renew)
Whether named institutional defendant and Mayor are proper parties	Crockett named DCPS and Mayor; he concedes Mayor improper	Defendants moved to dismiss DCPS and Mayor	Court: Substitutes District of Columbia for DCPS; dismisses Mayor from suit

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for plausibility)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility and dismissal standard)
Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (1984) (state-court judgments get preclusive effect under state law)
Semtek Int’l Inc. v. Lockheed Martin Corp., 531 U.S. 497 (2001) (Rule 41(b) dismissals and preclusion analysis)
Costello v. United States, 365 U.S. 265 (1961) (Rule 41(b) “for lack of jurisdiction” can include failure to satisfy preconditions)
Fry v. Napoleon Cmty. Schs., 137 S. Ct. 743 (2017) (IDEA §1415(l) and when exhaustion is required for related statutory claims)
Fitzgerald v. Barnstable Sch. Comm., 555 U.S. 246 (2009) (IDEA does not provide damages; interaction with other federal remedies)