Smith v. Rockwood R-VI School District, No. 17-2260 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's dismissal of the complaint, which alleged violations of the Individuals with Disabilities Education Act, the Rehabilitation Act of 1973, and 42 U.S.C. 1983. The court held that the Rehabilitation Act and section 1983 claims concerned the denial of a public education and thus plaintiffs were required to exhaust their administrative remedies first. Because plaintiffs failed to do so, these claims were properly dismissed. Likewise, the exhaustion requirement applied to the IDEA claim and no exception to the exhaustion requirement applied in this case.
Court Description: Wollman, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Civil case - Individuals with Disabilities Act. The district court did not err in dismissing plaintiffs' IDEA, Rehabilitation Act and Section 1983 claims after concluding plaintiffs had failed to exhaust their administrative remedies.
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