Key Legal Decisions
Embedded Files
Question Presented
What level of educational benefit must an IEP be designed to provide for a student to satisfy the IDEA’s requirement of a free appropriate public education (FAPE)?
The Court’s Holding
In a unanimous 8–0 decision, the Supreme Court rejected a lower “merely more than de minimis” standard, making clear that the IDEA requires more than minimal educational progress. The Court held that an IEP must be reasonably calculated to enable a child to make progress appropriate in light of the child’s individual circumstances.
Why the Decision Matters
Endrew F. established that the IDEA requires more than minimal educational progress. An IEP must be appropriately ambitious in light of the individual student’s circumstances, with every child given the opportunity to meet challenging objectives.
Read or listen to Endrew F. v. Douglas County School District on Oyez
Fry v. Napoleon Community Schools (2017)
Question Presented
Must a student first complete the IDEA's administrative process before bringing a disability-discrimination claim under the Americans with Disabilities Act (ADA) or Section 504 of the Rehabilitation Act?
The Court’s Holding
In a unanimous 8–0 decision, the Supreme Court held that IDEA exhaustion depends on whether the substance, or "gravamen," of the complaint concerns the denial of a free appropriate public education (FAPE), rather than simply the law under which the claim is brought.
The Court explained that a disability-discrimination claim does not automatically require IDEA exhaustion merely because it involves a student with a disability in a school setting.
Important Legal Update:
In Perez v. Sturgis Public Schools (2023), the Supreme Court further clarified that IDEA exhaustion is not required when a lawsuit seeks a remedy unavailable under the IDEA, such as compensatory damages, even when the underlying allegations involve a denial of FAPE.
Why the Decision Matters
Fry established an important framework for distinguishing disputes concerning the denial of FAPE from independent disability-discrimination claims under the ADA and Section 504.
Together, Fry (2017) and Perez (2023) clarify that courts must consider both the substance of the complaint and the relief requested when determining whether IDEA administrative exhaustion is required.
These decisions help protect the ability of students with disabilities and their families to pursue federal disability-discrimination claims without unnecessarily requiring IDEA administrative proceedings.
Perez v. Sturgis Public Schools (2023)
Question Presented
Must a student exhaust the IDEA’s administrative procedures before pursuing a claim under another federal disability law when the student seeks a remedy that the IDEA cannot provide?
The Court’s Holding
No. In a unanimous decision, the Supreme Court held that the IDEA’s exhaustion requirement does not bar a lawsuit under another federal law when the plaintiff seeks relief that the IDEA cannot provide. Because compensatory damages are unavailable under the IDEA, Perez was not required to exhaust the IDEA process before pursuing his ADA claim seeking those damages.
Why the Decision Matters
Perez clarified an important limit on IDEA exhaustion. A family seeking a remedy unavailable under the IDEA, such as compensatory damages, is not necessarily required to complete the IDEA administrative process before pursuing a claim under another federal disability law.
Read or listen to Perez v. Sturgis Public Schools on Oyez
A.J.T. v. Osseo Area Schools, Independent School District No. 279 (2025)
Question Presented
Must students with disabilities bringing education-related discrimination claims under the ADA or Section 504 satisfy a more demanding legal standard than people bringing disability-discrimination claims in other contexts?
The Court’s Holding
No. In a unanimous decision, the Supreme Court rejected the heightened “bad faith or gross misjudgment” standard that had been applied to certain education-related disability-discrimination claims. The Court held that students are subject to the same standards that generally apply to ADA and Section 504 claims outside the educational context.
Why the Decision Matters
A.J.T. removed a heightened legal barrier that made it more difficult for students with disabilities to pursue discrimination claims against schools. Students should not face a more demanding standard for establishing disability discrimination simply because the alleged discrimination occurred in an educational setting.
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