In E.D. v. Palmyra R-I School District, the Eighth Circuit Court of Appeals (the federal appeals court that includes South Dakota), a student with intellectual disabilities brought an action against the school district, alleging violations of Rehabilitation Act, Americans with Disabilities Act (ADA), and the Fourteenth Amendment, arising from the district's alleged failure to provide educational accommodations to the student.
The United States District Court granted summary judgment in favor of the school based on the student's failure to exhaust administrative remedies under the Individuals with Disabilities Education Act (IDEA). Student appealed. On appeal, the Eighth Circuit also found that the student was required under IDEA to exhaust administrative remedies before bringing action.
To read the court's full opinion - click here.