Supreme Court says deaf student can sue Michigan school district that denied qualified interpreter
The Supreme Court on Tuesday unanimously ruled in favor of a deaf student who sued his school district for denying his graduation after failing to provide him a qualified interpreter, as required under federal law.
In a 10-page opinion, the high court said the student’s initial settlement with the district under the Individuals with Disabilities Education Act did not preclude his separate lawsuit also against the district under the Americans with Disabilities Act, because he could seek financial compensation through the latter.
“A ‘remedy’ denotes ‘the means of enforcing a right’ and may come in the form of, say, money damages, an injunction or a declaratory judgment,” wrote Justice Neil M. Gorsuch, who authored the court’s opinion.
Miguel Luna Perez, the deaf student launching the legal battle, had asked the justices to let his lawsuit against the district proceed so he can be compensated financially for the violations of federal law.
Miguel attended Sturgis Public Schools in Michigan from ages 9 to 20. As a disabled student, he was entitled under federal law to free public education that meets his needs.
Miguel and his parents were under the impression he would be provided with a qualified classroom aide and sign language interpreter and be able to graduate on time. But they later were told by the school district that he qualified for only a “certificate of completion,” not a diploma.
They also learned the school district had provided Miguel an unqualified classroom aide, who was not trained to work with deaf students.
After discovering how Miguel had been treated, the family filed a complaint against the school district for violating the Individuals with Disabilities Education Act, which requires the school to meet a disabled student’s needs to achieve free public education.
The district settled the dispute with the family, agreeing to pay for post-secondary education and sign language instruction. Miguel was placed at Michigan School for the Deaf.
The family then filed a lawsuit in federal court, citing a violation of the Americans with Disabilities Act and seeking a financial award for violating Miguel’s rights because they could not obtain monetary damages under the first complaint.
The district court and the 6th U.S. Circuit Court of Appeals ruled against Miguel, saying because he settled under the Individuals with Disabilities Education Act, his other case was barred.
The high court reversed that decision, green-lighting Miguel’s case against the district over his Americans with Disability Act claims.
The district had argued Miguel did not exhaust his claims because he settled the initial complaint.
“Mr. Perez’s improper new argument that ‘settles’ equals ‘exhaustion’ is incorrect. An IDEA plaintiff cannot sue after settling,” said Shay Dvoretzky, who represented the district, during oral arguments earlier this year. “Redress can also bear a different meaning. … It’s the kind of situation where you might not get what you ask for, but you get what you need.”
The case is Perez v. Sturgis Public Schools.
