U.S. Supreme Court Issues Unanimous Decision in Fry v Napoleon Community Schools



On Wednesday February 26th, the U.S. Supreme Court issued an unanimous decision in favour of Fry after hearing the arguments on October 31, 2016. Fry v Napoleon Community Schools came to the Supreme Court from the Court of Appeals for the 6th circuit. 

The questions before the Supreme Court were:

(1) Exhaustion of the administrative procedures established by the Individuals with Disabilities Education Act is unnecessary when the gravamen of the plaintiff’s suit is something other than the denial of the IDEA’s core guarantee of a “free appropriate public education”; and

(2) the case is remanded to the U.S. Court of Appeals for the 6th Circuit for a proper analysis of whether the gravamen of E.F.’s complaint — which alleges only disability-based discrimination, without making any reference to the adequacy of the special-education services E.F.’s school provided — charges, and seeks relief for, the denial of a FAPE.

Considered a significant win for children with disabilities, the Court stated that when a lawsuit is filed under the Americans with Disabilities Act or the Rehabilitation Act, they do not have to go through the administrative proceedings required by the Individuals with Disabilities Education Act just because the alleged discrimination happened at a school. The Court further  stated that in determining a similar matter, courts should look at the complainant’s gravamen and the entirety of the dispute when deciding whether the complaint should have gone through the administrative system rather than the court. 

This blog post was written by a CCLA-PBSC RightsWatch student. Views expressed do not necessarily reflect the view of the CCLA or PBSC.