Legal Memorandum: Subject Matter Jurisdiction under IDEA

Issue: Do federal courts have subject matter jurisdiction to hear claims that arise under the Individuals with Disabilities Education Act?

Area of Law: Education Law, Litigation & Procedure
Keywords: Federal district court's jurisdiction; Claims arising under the IDEA; Federal statute
Jurisdiction: Federal
Cited Cases: 262 F. Supp. 2d 648; 175 F.3d 227; 273 F.3d 671
Cited Statutes: 20 U.S.C. § 1400; 28 U.S.C. §§ 1331 and 1341; 42 U.S.C. § 1983
Date: 05/01/2005

Because the Individuals with Disabilities Education Act (“IDEA”), 20 U.S.C. § 1400 et seq., is a federal statute, a claim arising under the IDEA is subject to the federal district court’s jurisdiction.  Ullmo v. Gilmour Acad., 273 F.3d 671, 680 (6th Cir. 2001).  Accord Virginia Office of Protection & Advocacy v. Virginia Department of Education, 262 F. Supp. 2d 648, 657 (E.D. Va. 2003) (federal district court has subject matter jurisdiction over IDEA claims).  Thus, for example, in Virginia Office of Protection, the federal district court rejected the defendant’s challenge to the plaintiff’s statement of subject matter jurisdiction.  The court found that it had subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1341, as well as under the IDEA.  Id., 262 F. Supp. 2d at 657-58. 

In addition, subject matter jurisdiction is conferred by 42 U.S.C. § 1983.  “Section 1983 provides a right of action against any person who, under color of state law, deprives another of ‘any rights, privileges or immunities secured by the Constitution and laws’ of the United States.”  Rodriguez v. Debuono, 175 F.3d 227, 232 (2d Cir. 1998) (quoting 42 U.S.C. § 1983).  As long as the plaintiff’s complaint states a colorable federal claim, subject matter jurisdiction exists.  Id. at 233 (holding that the plaintiff, who claimed the need for the court’s interpretation of two federal statutes, met the modest standard of “stat[ing] a right for which there was a judicially enforceable remedy”).


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