In the alternative, the relief approach focuses more on what sort of relief the plaintiff alleges in their complaint. The Ninth Circuit developed the relief approach in the aftermath of
Smith v. Robinson; 20 U.S.C. § 1415(l) was interpreted to mean that the existence of the ADA and Title V of the Rehabilitation Act logically meant that claims of relief must exist outside the scope of the IDEA because the IDEA was no longer the exclusive avenue for ensuring the rights of handicapped children.xxv Under the relief approach, if a plaintiff laid out a plausible claim for damages unrelated to the deprivation of free appropriate public education, then 20 U.S.C. §
5
1415(l) would not require exhaustion; litigants would be free to directly file a civil
Smith v. Robinson; 20 U.S.C. § 1415(l) was interpreted to mean that the existence of the ADA and Title V of the Rehabilitation Act logically meant that claims of relief must exist outside the scope of the IDEA because the IDEA was no longer the exclusive avenue for ensuring the rights of handicapped children.xxv Under the relief approach, if a plaintiff laid out a plausible claim for damages unrelated to the deprivation of free appropriate public education, then 20 U.S.C. §
5
1415(l) would not require exhaustion; litigants would be free to directly file a civil