The U.S. Supreme Court recently released its decision in Fry v Napoleon Community Schools. The justices unanimously held that exhaustion of the administrative procedures established by the Individuals with Disabilities Education Act (IDEA) 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.” For school districts and parents, the decision helps delineate the boundary between disability and education claims.
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