T.R. v. School District of Philadelphi, 4f4th179

Background

LEP parents sued the School District of Philadelphia alleging systemic failures to provide timely, complete translations and adequate interpreters for IEP-related documents and IEP Team meetings, impairing parental "meaningful participation" under the IDEA and related statutes.
The complaint sought class-wide injunctive relief (translated NOREP/PWN, draft/final IEPs, Procedural Safeguards Notices; new district policies) for two putative classes (Parent Class and Student Class).
Some original plaintiffs (A.G., T.R.) exhausted administrative remedies and obtained relief; the remaining named plaintiffs (Perez, Lin) had not exhausted administrative remedies when they sued.
The District Court denied class certification for lack of commonality/cohesion and later granted summary judgment for the School District, holding plaintiffs failed to exhaust administrative remedies and could not meet the narrow "systemic" exception to exhaustion; it also applied Fry to hold non‑IDEA claims sought relief for denial of a FAPE.
On appeal, the Third Circuit affirmed: it held (1) the systemic exception to IDEA exhaustion is limited to truly system‑wide defects (often those that undermine the administrative process itself), (2) plaintiffs’ challenge targeted a component of special‑education practice (translation/interpretation) requiring individualized inquiry, and (3) the non‑IDEA claims were grounded in the denial of a FAPE and thus subject to exhaustion.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs’ failure to exhaust IDEA administrative remedies should be excused by a "systemic" exception	Plaintiffs argued the District’s language‑services policies/practices were systemic and incapable of being remedied through individual administrative hearings, so exhaustion would be futile	District argued plaintiffs challenged discrete components (translation/interpretation) that require individualized inquiry and are remediable through administrative process	Held: systemic exception not met; plaintiffs challenged a component, not system‑wide policy that thwarts the administrative forum, so exhaustion required
Whether non‑IDEA claims (Rehab Act, ADA, Title VI, EEOA, PA law) are subject to IDEA exhaustion under Fry’s gravamen test	Plaintiffs contended Title VI/EEOA claims were distinct and did not seek relief for denial of a FAPE	District argued the gravamen of those claims was denial of meaningful participation/educational access and therefore sought relief also available under IDEA	Held: gravamen of non‑IDEA claims concerned denial of a FAPE; Fry applies; those claims are subject to IDEA exhaustion
Whether the district court’s denial of class certification affected plaintiffs’ ability to rely on a systemic exception	Plaintiffs argued class‑wide injunctive relief justified treating the claims as systemic and excusing exhaustion	District argued denial of class certification meant only individualized relief via administrative process was appropriate	Held: class posture did not transform component‑level claims into system‑wide defects; administrative remedies remained adequate

Key Cases Cited

Endrew F. v. Douglas Cnty. Sch. Dist. RE-1, 137 S. Ct. 988 (2017) (clarifies FAPE substantive standard under IDEA)
Fry v. Napoleon Cmty. Schs., 137 S. Ct. 743 (2017) (gravamen test for whether non‑IDEA claims require IDEA exhaustion)
Bd. of Educ. v. Rowley, 458 U.S. 176 (1982) (emphasizes importance of procedural safeguards and individualized IEP process)
Komninos v. Upper Saddle River Bd. of Educ., 13 F.3d 775 (3d Cir. 1994) (IDEA indicates plaintiffs must exhaust administrative remedies)
Beth V. v. Carroll, 87 F.3d 80 (3d Cir. 1996) (recognizes systemic exception to exhaustion in limited circumstances)
Hoeft v. Tucson Unified Sch. Dist., 967 F.2d 1298 (9th Cir. 1992) (systemic exception limited to defects that threaten IDEA’s basic goals or administrative forum)
Mrs. W. v. Tirozzi, 832 F.2d 748 (2d Cir. 1987) (examples where administrative process is inadequate because plaintiffs challenge the framework/procedures themselves)
D.E. v. Cent. Dauphin Sch. Dist., 765 F.3d 260 (3d Cir. 2014) (sets out recognized exceptions to exhaustion)
Wellman v. Butler Area Sch. Dist., 877 F.3d 125 (3d Cir. 2017) (applies Fry and analyzes when non‑IDEA claims implicate a FAPE)