Fry v. Napoleon Community Schools
| Fry v. Napoleon Community Schools | |
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| Argued October 31, 2016 Decided February 22, 2017 |
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| 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 nos. | 15–497 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| 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. | |
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| 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. ___ (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).
Minor Ehlena Fry was born with spastic quadriplegic cerebral palsy, which significantly impairs her motor skills and mobility. Ehlena Fry, originally in an orphanage in Calcutta, India, was adopted by Stacy and Brent Fry. In 2008, Fry's pediatrician prescribed a service dog for Ehlena; the community ran a fundraiser so that the Fry family could purchase a service dog for their adopted daughter. The service dog Wonder would help Ehlena Fry, amongst other things, open doors, turn on lights, pick up dropped items, help her remove her coat, and help her balance while she transferred from her walker onto a chair or the toilet. The administration of Ezra Eby Elementary School (one of the Napoleon Community Schools), however, denied permission to bring her service dog to school for the 2009-2010 school year. Under the Individuals with Disabilities Education Act, schools are obligated to provide disabled children the Individualized Education Program (IEP) in order to provide them free appropriate public education (FAPE). The school district argued that a human aide can provide all the necessary help so that Ehlena Fry can get free and appropriate public education. The school's decision to prohibit Wonder was upheld in the meeting held in January 2010 related to Fry's IEP. The Fry family maintained that the service dog, which had time to bond with Ehlena, is necessary as a bridge to her independence, and that the right to bring her service dog is covered by the Americans with Disabilities Act (ADA).
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