Federal District Court Finds That Exhaustion Is Still The Rule When the Essence of a Complaint Seeks Remedies Available under the IDEA

06.12.2025

On March 4, 2025, Plaintiff, on behalf of her special education student, filed a complaint in the United States District Court for the Central District of California, requesting that the Court order the Saugus Union School District (“District”) to convene a Section 504 of the Rehabilitation Act of 1973 (“Section 504”) hearing as required by 34 C.F.R Section 104.36. Plaintiff filed the Complaint in order to enforce her right to a Section 504 hearing because she alleged that the District refused to appropriately accommodate her student, and denied her request for a Section 504 hearing. Plaintiff also alleged that the District denied student a free appropriate public education (“FAPE”) because the District refused the accommodations she requested. However, Plaintiff’s complaint alleged that she was only seeking an order requiring the District to convene a Section 504 hearing in response to her request.

In response, the District filed a Motion to Dismiss Plaintiff’s complaint on the grounds that Plaintiff failed to exhaust her administrative remedies under the Individuals with Disabilities Education Act (“IDEA”) before filing her complaint. In this case, the student was eligible for and received special education and related services under the IDEA.

On May 29, 2025, the Court granted the District’s Motion and dismissed Plaintiff’s complaint in its entirety, with prejudice. (S. Moses v. Saugus Union School District Case No. 2:25-cv-01567-CBM-BFM).The Court held that while Plaintiff alleged that she was only seeking an order that the District be required to hold a Section 504 hearing, the gravamen of [the Complaint] seeks redress for the District’s failure to provide a FAPE, and the relief she actually sought is available to her under the IDEA. As a result, Plaintiff could not avoid the exhaustion requirement under 20 U.S.C. § 1415. The Court also concluded that to the extent Plaintiff maintains that she is entitled to a Section 504 hearing, the appropriate recourse available to her is to file a complaint with the U.S. Department of Education’s Office of Civil Rights (“OCR”).

This is an important ruling for districts and reaffirms the requirement that plaintiffs exhaust their administrative remedies under the IDEA before they will be permitted to proceed in federal court. It also helps to prevent districts from having to potentially defend against multiple administrative hearings (Section 504 and due process) before facing further litigation in federal court. However, based on the Court’s language that Plaintiff could seek relief from OCR, districts may see an increase in filings with the OCR over Section 504 claims. We encourage you to consult with your legal counsel if you receive similar requests for Section 504 hearings, and we will update you if there are any further legal developments.

This AALRR publication is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. Applicability of the legal principles discussed may differ substantially in individual situations. Receipt of this or any other AALRR publication does not create an attorney-client relationship. The Firm is not responsible for inadvertent errors that may occur in the publishing process.

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