Stacy Fry, as Next Friends of Minor E.f., Petitioners v. Napoleon Community Schools

Summary

The Supreme Court held that 20 U.S.C. § 1415(l) requires a plaintiff suing under the ADA, the Rehabilitation Act, or similar statutes to exhaust the IDEA's administrative procedures only when the gravamen of her complaint seeks relief for the denial of a free appropriate public education (FAPE), because FAPE-denial relief is the only relief the IDEA makes available. Courts must look past labels to the substance of the complaint, aided by indicators such as whether the same claim could be brought against a non-school public facility or by an adult, and whether the plaintiff previously invoked the IDEA's formal procedures. Because the Sixth Circuit had instead asked whether the child's injuries were broadly 'educational,' the Court vacated and remanded for application of the gravamen analysis, including inquiry into any prior IDEA proceedings. Justice Alito, joined by Justice Thomas, concurred in part and in the judgment, objecting that the Court's suggested 'clues' for lower courts wrongly presuppose no overlap between IDEA relief and relief under other statutes and may confuse rather than assist.