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ADA Claim Arising from Alleged Denial of FAPE Requires Exhaustion of Administrative Process

The recent en banc opinion of the U.S. Court of Appeals for the Ninth Circuit, D.D. v. Los Angeles Unified School District (9th Cir. 2021) 18 F.4th 1043, addresses the issue of whether a plaintiff asserting a claim in federal court under the Americans with Disabilities Act (ADA) must first pursue available administrative remedies under the Individuals with Disabilities Education Act (IDEA

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