Whether the Individuals with Disabilities Education Act (IDEA) requires administrative exhaustion for non-IDEA claims seeking relief not available under IDEA

QUESTION PRESENTED This case presents the question that this Court granted certiorari to review, but then expressly left open, in Fry v. Napoleon Community Schools, 137 S. Ct. 7438, 752 & n.4, 754 n.8 (2017), and that continues to divide the circuits: Whether the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1400 et seg., requires administrative exhaustion when a plaintiff brings a nonIDEA claim seeking relief that is not available under the IDEA.