Perez v. Sturgis Public Schools

Jump to content

From Wikipedia, the free encyclopedia

(Redirected from Perez v. Sturgis Public Schools )

2023 United States Supreme Court case

Luna Perez v. Sturgis Public Schools, 598 U.S. 142 (2023), was a United States Supreme Court decision in which the Court held that an Americans with Disabilities Act (ADA) lawsuit seeking compensatory damages for denial of a Free and Appropriate Public Education (FAPE) can proceed without exhausting the administrative procedures of the Individuals with Disabilities Education Act (IDEA), because compensatory damages are not available under IDEA.

This case holds significant implications for disabled students who allege they were failed by school officials.

Background

[(https://en.wikipedia.org/w/index.php?title=Luna_Perez_v._Sturgis_Public_Schools&action=edit&section=1 "Edit section: Background")
]

After moving from Mexico to the US, Miguel Luna Perez, a deaf student, attended schools in Michigan's Sturgis Public Schools District from the ages of 9 to 20, a 12 year period from 2004 to 2016.

Under his individualized education program (IEP), Sturgis schools were to provide classroom aides who interpreted to translate classroom instruction into sign language . However, Perez's parents alleged that Sturgis failed to provide qualified interpreters. In fact, Sturgis never provided Perez with a qualified sign language interpreter. Notably, one aide/interpreter assigned to Perez from approximately 2006 to May 2016, Gayle Cunningham, did not know sign language but did attempt to teach herself. Cunningham never had any official training or certification in sign language. Cunningham was Perez's sole facilitator of communication in the classroom. It was also alleged the district failed to properly evaluate her interpreting ability and misrepresented her skills and abilities to Perez's family.

Cunningham "essentially invented the signing system she used" and her "command of sign language remained so poor that, when briefly paired with a different deaf student who used sign language, the other deaf student could not understand her at all." Perez had no way of knowing what was actually being said around him because he had no independent understanding of what was being said. Perez's parents further alleged that the interpreters were absent from class for hours on end.

This was because, beginning in 2015, Cunningham was given other duties away from Perez, leaving him with no means to communicate with others. It was alleged that he was learning nothing in his classes due to the absence of a qualified sign language interpreter. Perez was also excluded from the English Language Learner program that the school district offered as an extracurricular activity because he was deaf.

Sturgis Schools misrepresented Perez's educational progress and academic achievement, awarding him inflated grades and advancing him no matter his actual progress. He was given As and Bs in nearly every class and was on the Honor Roll every semester. His parents had assumed that he was on track to earn a high-school diploma. In March 2016, just months before his anticipated graduation from high school that June, he and his parents were informed he would not be awarded a high school diploma but a certificate of completion.

Michigan Department of Education Administrative Complaint

[(https://en.wikipedia.org/w/index.php?title=Luna_Perez_v._Sturgis_Public_Schools&action=edit&section=2 "Edit section: Michigan Department of Education Administrative Complaint")
]

In response to these revelations, Perez and his family filed an administrative complaint in December 2017 with the Michigan Department of Education (MDE).

The complaint alleged Sturgis denied him an adequate education and violated several federal and state disability laws: the Individuals with Disabilities Education Act (IDEA), the Americans with Disabilities Act (ADA), the Rehabilitation Act , and two Michigan disabilities laws. The complaint alleged that Sturgis Public Schools had failed to meet its requirements under the IDEA and did not provide Perez with a Free Appropriate Public Education (FAPE).

In June 2018 a written settlement offer was provided to Perez's family from the school district. Prior to a hearing before the MDE, the Perez family and Sturgis Public Schools settled the IDEA/FAPE complaint. Sturgis Schools agreed to provide Perez with all the "forward-looking equitable relief he sought," including paying for Perez to attend the Michigan School for the Deaf (MSD) in Flint . Perez eventually graduated from MSD in June 2020 with a high school diploma. The school district also agreed to pay for "post-secondary compensatory education", for sign language instruction for Perez and his family and the family's attorney's fees. The Administrative Law Judge (ALJ) dismissed the case and remaining claims in August 2018 with prejudice.

Federal District Court holding

[(https://en.wikipedia.org/w/index.php?title=Luna_Perez_v._Sturgis_Public_Schools&action=edit&section=3 "Edit section: Federal District Court holding")
]

In December 2018, Perez and his family filed a federal complaint against the school district in the United States District Court for the Western District of Michigan under the Americans with Disabilities Act (ADA).

It was alleged the school discriminated against him by not providing the resources necessary for him to participate fully in class. Along with declaratory relief, Perez sought compensatory damages for his emotional distress.

Sturgis Schools filed a motion and argued that IDEA 20 U. S. C. §1415(l), barred Perez from bringing an ADA claim without first exhausting all of IDEA's administrative dispute resolution procedures. The district court agreed with Sturgis and granted the Sturgis motion, and dismissed the litigation. The District Court dismissed the ADA claim for failure to exhaust and declined to exercise supplemental jurisdiction over the remaining state-law claims. Perez and his family filed a timely appeal to the United States Court of Appeals for the Sixth Circuit .

Sixth Circuit holding

[(https://en.wikipedia.org/w/index.php?title=Luna_Perez_v._Sturgis_Public_Schools&action=edit&section=4 "Edit section: Sixth Circuit holding")
]

The case was argued October 9, 2020, before a three judge panel in the United States Court of Appeals for the Sixth Circuit . The court issued its opinion on June 25, 2021. It was argued before Judge Danny Julian Boggs , Jane Branstetter Stranch , and [Amul Thapar](https://en.wikipedia.or

…