In Perez, the Supreme Court held: (1) IDEA's administrative exhaustion requirement applies only to suits brought under another federal law that seek relief also available under IDEA; and (2) the student was not required to exhaust administrative procedures under IDEA before seeking relief in the form of compensatory damages under ADA.

In Perez, the district court held, and the Sixth Circuit affirmed, that 20 U.S.C. § 1415(1) barred the plaintiff from bringing an ADA cause because it requires a plaintiff “seeking relief that is also available under” IDEA to first exhaust IDEA's administrative procedures.

In Perez, the plaintiff fully resolved his administrative complaint under the IDEA, obtained all forwardlooking equitable relief he requested (including additional schooling), and later, in an independent action, unambiguously sought “backward-looking relief in the form of compensatory damages” under the Americans with Disabilities Act.