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15-497 FRY V. NAPOLEON COMMUNITY SCHOOL DECISION BELOW: 788 F.3d 622 CERT. GRANTED 6/28/2016 QUESTION PRESENTED: The Handicapped Children's Protection Act of 1986 (HCPA), 20 U.S.C. § 1415(l), requires exhaustion of state administrative remedies under the Individuals with Disabilities Education Act (IDEA) for non-IDEA actions "seeking relief that is also available under" the IDEA. The question presented, on which the circuits have persistently disagreed, is: Whether the HCPA commands exhaustion in a suit, brought under the Americans with Disabilities Act and the Rehabilitation Act, that seeks damages-a remedy that is not available under the IDEA. LOWER COURT CASE NUMBER: 14-1137
In the 2016 case of Fry v. Napoleon Community Schools, the U.S. Supreme Court ruled in favor of a student with cerebral palsy who was denied permission to bring her service dog to school. The court held that Ehlena Fry and her parents could bypass administrative procedures under the Individuals with Disabilities Education Act (IDEA) because their lawsuit was not about the appropriateness of an education plan but rather about access rights under Americans with Disabilities Act (ADA) and Rehabilitation Act. These laws prohibit discrimination on basis of disability in public places and services, including schools. The Frys argued that denying Ehlena's service dog at school violated these acts as it limited her ability to fully participate and benefit from attending classes just like any other student without disabilities would do so.
In the dissenting opinion for Fry v. Napoleon Community Schools, Justice Alito, joined by Justice Thomas, expressed concern over the majority's interpretation of the Individuals with Disabilities Education Act (IDEA). They argued that it could lead to confusion and unnecessary litigation because it did not provide clear guidance on when a lawsuit is about a denial of Free Appropriate Public Education (FAPE) or other forms of discrimination. The dissenters believed that if an alleged injury is related to special education services - even if FAPE isn't explicitly mentioned in the complaint - then IDEA procedures should be followed before resorting to court action. This would ensure consistency and avoid potential conflicts between different federal laws protecting disabled students' rights.