Luna Perez v. Sturgis Public Schools, 598 U.S. 142

Miguel Luna Perez, who is deaf, attended Sturgis Public Schools in Michigan from ages 9–20 and relied on interpreters/aides for instruction.
Perez and his parents allege the district provided unqualified or absent interpreters, misrepresented his academic progress, and ultimately refused to award him a diploma.
They filed an IDEA administrative complaint; the parties settled before a due‑process hearing, with Sturgis agreeing to forward‑looking equitable relief (additional schooling).
After the administrative settlement, Perez sued the district under the ADA seeking backward‑looking compensatory damages.
The district moved to dismiss, citing IDEA §1415(l)’s exhaustion requirement; the district court dismissed and the Sixth Circuit affirmed.
The Supreme Court granted certiorari to resolve whether §1415(l) bars ADA suits seeking compensatory damages that IDEA cannot provide.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether IDEA §1415(l) requires exhaustion of IDEA administrative procedures before bringing an ADA suit for compensatory damages	§1415(l) requires exhaustion only when the plaintiff seeks relief that is also available under IDEA; compensatory damages are not available under IDEA, so exhaustion not required	§1415(l) requires exhaustion for suits that seek redress for the same education‑related harms IDEA addresses, even if the remedy sought (like damages) is different	The Court held exhaustion is required only when the plaintiff seeks relief that is also available under IDEA; because compensatory damages are not available under IDEA, §1415(l) did not bar Perez’s ADA claim

Fry v. Napoleon Cmty. Schs., 580 U.S. 154 (2017) (addressed §1415(l) exhaustion; reserved the precise question presented here)
Henson v. Santander Consumer USA Inc., 582 U.S. 79 (2017) (courts must apply statutory text and not substitute speculative congressional intent)
Magwood v. Patterson, 561 U.S. 320 (2010) (same principle about applying statutory text)
School Comm. of Burlington v. Dep’t of Ed. of Mass., 471 U.S. 359 (1985) (IDEA authorizes courts to grant certain relief as available remedies)
South Carolina v. North Carolina, 558 U.S. 256 (2010) (uses phrasing treating the "relief sought" as the remedies requested)
Bowen v. Massachusetts, 487 U.S. 879 (1988) (discusses actions seeking relief other than money damages)
Perez v. Sturgis Pub. Schs., 3 F.4th 236 (6th Cir. 2021) (Sixth Circuit affirmed dismissal under §1415(l))
Covington v. Knox Cty. Sch. Sys., 205 F.3d 912 (6th Cir. 2000) (earlier Sixth Circuit precedent interpreting IDEA exhaustion)