Case: Perez v. Sturgis Public Schools
1:18-cv-01134 | U.S. District Court for the Western District of Michigan
Filed Date: Oct. 2, 2018
Closed Date: Oct. 18, 2023
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Case Summary
On October 2, 2018, a deaf student filed this lawsuit in the U.S. District Court for the Western District of Michigan against Sturgis Public Schools and the Sturgis Public Schools Board of Education. The plaintiff was represented by Michigan’s Protection and Advocacy (P&A) Service and the National Association of the Deaf Law and Advocacy Center. The plaintiff sued under Section 504 of the Rehabilitation Act, the Americans with Disabilities Act (the ADA), and Michigan’s Persons with Disabilities Civil Rights Act (PDCRA). The complaint asked for damages and attorneys’ fees, and equitable and injunctive relief.
The complaint alleged that the defendants discriminated against the plaintiff while he was a student in Sturgis Public Schools by failing to provide a qualified sign language interpreter and failing to provide access to social events and other extracurricular activities. Per the complaint, from 2004 to 2016, the defendants failed to provide the plaintiff with the auxiliary services necessary for him to participate in school. Further, when the plaintiff first arrived at Sturgis in 2004, he did not speak English and only spoke Spanish at home, but Sturgis did not provide English Language Learner (ELL) services. The complaint alleged that Sturgis provided ELL services to all other students who spoke a non-English language at home, but did not do so for the plaintiff, solely because he is deaf. The complaint also alleged that the plaintiff relied on signing to communicate, but instead of providing a qualified sign language interpreter to enable the plaintiff to engage in the classroom, Sturgis assigned an educational assistant who did not know sign language and had no relevant credentials. This educational assistant was the plaintiff’s only communication facilitator from 2006-2015. During that time, Sturgis allegedly provided qualified sign language interpreters to another deaf student. The plaintiff’s parents, who did not speak English, relied on Sturgis’ representations that the educational assistant was qualified to work with the plaintiff. They only saw that their son was receiving A’s and B’s in all of his classes, which misrepresented the plaintiff’s access to what was being taught in class. The plaintiff did not know that the educational assistant was not qualified, because he did not know English sign language and had never worked with a qualified sign interpreter. The plaintiff allegedly had such little access to education that by 2016, he could not read or write, and did not know the words for many of the foods he regularly ate.
In 2015, Sturgis took away the educational assistant and enrolled the plaintiff in “web-based learning,” despite the plaintiff’s inability to read or write. The complaint alleged that Sturgis did this solely because the plaintiff was deaf. Because they thought his classes had been fully accessible, the plaintiff’s parents believed that the plaintiff would be graduating with a high school diploma. Instead, Sturgis gave the plaintiff a certificate of completion. The plaintiff claimed that he was deprived of the equal opportunity to receive education and that as a result of the defendants’ violation of Section 504 of the Rehabilitation Act he suffered severe emotional distress. The case was assigned to Judge Paul L. Maloney.
On December 3, 2018, the plaintiff filed an amended complaint, which added information on his administrative due process claim that had been filed prior to the court complaint and that had alleged violations of the Individuals with Disabilities Education Act (IDEA), Section 504 of the Rehabilitation Act, the ADA, the PDCRA, and Michigan Administrative Rules for Special Education (MARSE). Adjudication pursuant to IDEA and MARSE may occur in administrative proceedings, rather than in court. On May 18, 2018, the administrative law judge had dismissed all claims brought pursuant to the ADA, the Rehabilitation Act, and the PDCRA for lack of jurisdiction. On August 15, 2018, the administrative law judge dismissed with prejudice all claims brought under IDEA and MARSE, after the parties reached an agreement resolving those claims. It was after the conclusion of this administrative procedure that the plaintiff filed this action in district court.
On December 20, 2018, the defendants filed a motion to dismiss, arguing that the plaintiff had not exhausted his administrative remedies prior to filing suit in court, as required by IDEA. On June 20, 2019, Magistrate Judge Ray Kent filed a report and recommendation, finding that IDEA’s exhaustion requirement—the requirement that a plaintiff exhaust all administrative remedies before filing suit in court—applied to this case because IDEA’s exhaustion requirement hinges on whether a lawsuit seeks relief for the denial of a free appropriate public education (FAPE). Since the plaintiff alleged such a denial, by alleging the defendants’ failure to provide him a certified sign language interpreter, the exhaustion requirement applied. Although IDEA did not preclude relief under other statutes like the ADA or Rehabilitation Act, if the relief sought under such statutes in a court case was also available under IDEA, administrative remedies must be exhausted first. Dismissal of his IDEA claim by the administrative law judge did not constitute exhaustion of all of his FAPE-related claims. Thus, the magistrate judge recommended that the court grant the defendants’ motion to dismiss.
On December 19, 2019, the court adopted the magistrate judge’s report and recommendation as the opinion of the court and granted the motion to dismiss. The plaintiff appealed this dismissal to the U.S. Court of Appeals for the Sixth Circuit on January 17, 2020. On June 25, 2021, the Sixth Circuit affirmed the decision of the district court to dismiss this action. When seeking relief under IDEA, the main consideration was the nature of the harm, not the kind of relief sought, meaning that a lawsuit that sought relief for the denial of a FAPE was subject to the exhaustion requirement, even if it requested a remedy the IDEA did not allow. Here, the plaintiff’s core complaint is that the school denied him a FAPE, so his suit sought relief that is available under IDEA. Thus, because the suit sought relief available under IDEA, the decision to settle precluded the plaintiff from bringing a similar case against the school in federal court, even under a different federal law. 3 F.4th 236.
On December 17, 2021, the plaintiff filed a petition for a writ of certiorari to the United States Supreme Court. On October 11, 2022, the Supreme Court agreed to hear the case. The Court heard oral argument on January 18, 2023. On March 21, 2023, in a unanimous opinion authored by Justice Gorsuch, the Supreme Court ruled in favor of the plaintiff, reversing the lower court’s decision and remanding for further proceedings. Using strict textual analysis, the Court found that generally, the text of IDEA barred individuals from “seeking relief” under other federal laws unless they first exhausted administrative remedies. But this limiting language did not apply to all suits seeking relief that other federal laws provided. The statute's administrative exhaustion requirement applied only to suits that sought relief also available under IDEA. That condition was not met in the current case, where the plaintiff brought a suit under another federal law for compensatory damages—a form of relief that all parties agreed IDEA does not provide. Thus, the Court held that IDEA’s exhaustion requirement did not preclude the plaintiff’s ADA lawsuit because the relief sought in the ADA case—compensatory damages—was not something IDEA could provide. 598 U.S. 142.
On April 24, 2023, the U.S. Court of Appeals for the Sixth Circuit vacated the judgement of the district court, and remanded the case for further proceedings in the district court.
In the district court, a settlement conference between the parties was set for September 12, 2023. As a result of their settlement agreement, the parties filed a stipulation and proposed order of dismissal with prejudice on October 18, 2023. The details of the settlement agreement are private.
On October 18, 2023, the court closed the case.
Summary Authors
Kady Matsuzaki (4/2/2023)
Skylar Parpan (11/9/2025)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/7984676/parties/perez-v-sturgis-public-schools/
Maloney, Paul Lewis (Michigan)
Cody, Mark A. (Michigan)
Jackson, Caroline Elaine (Michigan)
Martinez, Roman
Chapie, Kenneth B. (Michigan)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/7984676/perez-v-sturgis-public-schools/
Last updated July 8, 2026, 5:27 a.m.
Docket for: Perez v. Sturgis Public Schools
Case Details
State / Territory:
Case Type(s):
Healthcare Access and Reproductive Issues
Key Dates
Filing Date: Oct. 2, 2018
Closing Date: Oct. 18, 2023
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A deaf student who attended Sturgis Public Schools from 2004-2016.
Plaintiff Type(s):
Attorney Organizations:
NDRN/Protection & Advocacy Organizations
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
School District
Sturgis Public Schools
Sturgis Public Schools Board of Education
Defendant Type(s):
Case Details
Causes of Action:
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12111 et seq.
Section 504 (Rehabilitation Act), 29 U.S.C. § 701
Other Dockets:
Western District of Michigan 1:18-cv-01134
U.S. Court of Appeals for the Sixth Circuit 20-01076
Supreme Court of the United States 21-887
Supreme Court of the United States 21A74
Available Documents:
U.S. Supreme Court merits opinion
Outcome
Prevailing Party: Plaintiff OR Mixed
Relief Sought:
Relief Granted:
Source of Relief:
Form of Settlement:
Issues
General/Misc.:
Staff (number, training, qualifications, wages)
Disability and Disability Rights:
Discrimination Basis:
Disability (inc. reasonable accommodations)
Case Summary of Perez v. Sturgis Public Schools, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/44050/ (last updated 11/9/2025).