Student A v. San Francisco Unified School District

Background

Five current or former San Francisco Unified School District students sued the district and Superintendent Vincent Matthews. They alleged systemic failures involving students with disabilities under the Individuals with Disabilities Education Act, Section 504 of the Rehabilitation Act, and the Americans with Disabilities Act. Their allegations concerned the district’s alleged failures to identify and evaluate students, offer individualized special-education services, and provide the services required by students’ individualized education programs.

The plaintiffs sought a total restructuring of the district’s special-education system for disabled students throughout San Francisco. Their factual allegations, however, focused mainly on the individual experiences of the five named students, who had dyslexia, autism, or speech and language impairments. The complaint also cited district-wide data and state performance findings.

Exhaustion requirement

The court explained that claims seeking a free appropriate public education under the Individuals with Disabilities Education Act generally must first go through available administrative procedures. In California, those procedures include an individualized due-process hearing through the Office of Administrative Hearings and a complaint-resolution process through the California Department of Education.

The court also concluded that the plaintiffs’ Section 504 claims were subject to the same exhaustion requirement because the plaintiffs acknowledged that the case concerned the denial of a free appropriate public education. The court stated that the Americans with Disabilities Act claims were intertwined with and duplicative of the Individuals with Disabilities Education Act and Section 504 claims.

Exhaustion may be excused in limited circumstances, including when administrative proceedings would be futile, when a generally applicable policy violates the law, or when adequate relief is unlikely to be available administratively. The court emphasized that seeking broad or system-wide relief does not by itself excuse exhaustion.

Court’s analysis

The court found that the plaintiffs were challenging alleged failures to implement existing requirements, rather than generally applicable official policies that were unlawful on their face. The alleged failures involved identifying students, providing individualized services, and supplying enough funding, staff, and resources to carry out students’ education plans.

The court reasoned that administrative proceedings could help develop a factual record about the district’s conduct, allow the district and state to respond, and give the state an opportunity to address some or all of the alleged problems. The fact that the individualized hearing process could not award the plaintiffs all of their requested system-wide relief did not eliminate the usefulness of that process.

The court further concluded that the state complaint-resolution process could provide an appropriate way to alert the state to the plaintiffs’ broad allegations. No plaintiff had used either administrative process, and the plaintiffs did not allege facts showing that using those procedures would be futile. The court also found that the amended complaint did not plausibly establish an emergency requiring immediate court intervention or show that the limited allegations about five students demonstrated a total failure of the district’s special-education system across all grades and disabilities.

Disposition

Judge William H. Orrick granted the defendants’ motion to dismiss for failure to exhaust administrative remedies. Because the plaintiffs had already been given an opportunity to add facts supporting an exception to exhaustion but had not done so, the court dismissed the case with prejudice. The court did not reach Superintendent Matthews’s separate argument that the claims against him were redundant of the claims against the school district.