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] Minor Ehlena Fry was born with spastic quadriplegic cerebral palsy, which significantly impairs her motor skills and mobility.

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.

During that time, the Frys filed a complaint to the Office of Civil Rights of the United States Department of Education, which issued a determination letter that the school violated Ehlena Fry's rights protected by the Americans with Disabilities Act "by failing to modify their policies, practices, or procedures to permit the student's service animal to accompany her to and assist her at school, thus denying and/or significantly limiting the student's ability to access the district's programs and activities with as much independence as possible".

The Frys countered that since they seek for the declaratory judgement that the school violated the ADA and money damages for emotional distress, both of which are not the type of remedies available under the IDEA.

Title II of the ADA mandates public facilities to make "reasonable modifications" to avoid discriminating against people with disabilities.

The Frys appealed and argued that the exhaustion requirement did not apply because they were seeking damages, which is not the sort of relief the IDEA provided.

The majority of the Sixth Circuit held that the Frys’ claims were essentially educational—particularly, they noted that "developing a bond with Wonder that allows E.F. to function more independently outside the classroom is an educational goal".

Judge Daughtrey wrote that since Frys' request to bring Wonder to school was not related to Ehlena's academic program – hence not educational in nature – there is no reason for the administrative remedy exhaustion requirement to apply.

The federal government also filed a brief recommending that the Supreme Court grant the writ of certiorari, arguing that the Sixth Circuit incorrectly decided the case in favour of the respondents.

Amicus briefs in support of the Fry family were filed by National Disability Rights Network, Council of Parent Attorneys and Advocates, Psychiatric Service Dog Partners, and Autism Speaks.

The opinion, quoting Black's Law Dictionary, noted that the "relief" for lawsuits means the "redress or benefit" that can be conferred upon a favourable judgement.

Thus, in the Court's view, analyzing when the IDEA enables a person to obtain relief is paramount to determining the scope of the exhaustion requirement.

The court's opinion noted that the Congress declared the IDEA is "to ensure that all children with disabilities have available to them a free appropriate public education" (quoting §1400(d)(1)(A)).

Therefore, the IDEA's administrative remedies are meant to test whether a school completed their obligation to provide a child meaningful access to a free appropriate public education – in other words, "a FAPE denial is the sine qua non".

However, even though another law besides the IDEA may require an accommodation on alternative grounds, the officer nonetheless cannot order such relief if it does not touch on a FAPE denial.

Since it is possible for a school's refusal to allow certain accommodation to injure a child in a way that is unrelated to a FAPE, in such circumstances the administrative remedy exhaustion does not apply.

For instance, suppose that a student with a learning disability sues his school under the ADA for failing to provide additional tutoring in mathematics.

If a plaintiff formally invoked the IDEA's administrative procedures before switching the course, that can possibly suggest that the gravamen of the complaint is related to a FAPE denial.

Specifically, Alito wrote that the court's test would work well only if there is no overlap between the relief available under the IDEA and the relief provided by other federal laws (including the Rehabilitation Act, Americans with Disabilities Act (ADA), the United States Constitution, inter alia), yet the court admitted that there may be instances when there is such overlap.

Michael Steinberg, the legal director of the American Civil Liberties Union in Michigan, which has represented Fry throughout her legal proceedings, praised the ruling, stating that "[w]e're thrilled that the Supreme Court has torn down unfair barriers faced by students who seek to vindicate their rights under the Americans with Disabilities Act".

[11] Stacy Fry, Ehlena's mother, also praised the ruling in her statement: "[w]e are thankful that the Supreme Court has clarified that schools cannot treat children with disabilities differently or stand in the way of their desired independence.

Naomi Gittins, the managing director of legal advocacy for the NSBA, stated that "[g]oing right to court is never a good approach when you're talking about educational issues[.]

[11] Writing for SCOTUSblog, Amy Howe wrote that the Court's ruling is "a significant win – not only for [Ehlena Fry] and her family, but also for children with disabilities nationwide".