Miguel Luna Perez, a deaf student who attended schools in Michigan's Sturgis Public School District, was denied graduation. his family filed a complaint with the Michigan Department of Education claiming that the district failed to provide him with a free and appropriate public education under the Individuals with Disabilities Education Act (IDEA). The parties reached a settlement, and Perez then sued under the Americans with Disabilities Act (ADA), seeking compensatory damages, but the district court dismissed the suit, and the Sixth Circuit affirmed; based on IDEA's requirement that plaintiffs exhaust administrative procedures before seeking relief that is also available under IDEA. HELD: The Individuals with Disabilities Education Act does not require Perez to exhaust administrative remedies before filing an action, because IDEA does not provide for compensatory damages. Support the show