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.
Judgment: Vacated and remanded, 8-0, in an opinion by Justice Kagan on February 22, 2017. Justice Alito filed an opinion concurring in part and concurring in the judgment, in which Justice Thomas joined.
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