Fry v. Napoleon Community Schools

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Fry v. Napoleon Community Schools
Supreme Court of the United States
Argued October 31, 2016 Decided February 22, 2017
Full case name	Stacy Fry and Brent Fry, as next friends of minor E.F. v. Napoleon Community Schools, Pamela Barnes, Jackson County Intermediate School District
Docket no.	15-497
Citations	580 U.S. 154 (more) 137 S. Ct. 743; 197 L. Ed. 2d 46
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	788 F.3d 622 (6th Cir. 2015); cert. granted, 136 S. Ct. 2540 (2016).
Subsequent	See the Subsequent development section
Holding
Exhaustion of the Individuals with Disabilities Education Act's (IDEA's) administrative procedures is unnecessary where 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 (FAPE). Furthermore, the court should properly analyze the gravamen of a plaintiff's charges to determine if those charges seek relief for a denial of FAPE, per the test set out by the Court (see below for more information on this). The Sixth Circuit vacated and remanded.
Court membership
Chief Justice John Roberts Associate Justices Anthony Kennedy · Clarence Thomas Ruth Bader Ginsburg · Stephen Breyer Samuel Alito · Sonia Sotomayor Elena Kagan
Case opinions
Majority	Kagan, joined by Roberts, Kennedy, Ginsburg, Breyer, Sotomayor
Concurrence	Alito (in part), joined by Thomas
Laws applied
Handicapped Children's Protection Act of 1986, Individuals with Disabilities Education Act, Americans with Disabilities Act, Rehabilitation Act

Fry v. Napoleon Community Schools, 580 U.S. 154 (2017), is a United States Supreme Court case in which the Court held that the Handicapped Children's Protection Act of 1986 does not command exhaustion of state-level administrative remedies codified in the Individuals with Disabilities Education Act (IDEA) when the gravamen of the plaintiff's lawsuit is not related to the denial of free appropriate public education (FAPE).^[1]