was seeking monetary damages for physical and verbal abuse by spe cial education school officials, was not required to exhaust formal administrative remedies, because the parties had already informally agreed to provide the injured child with all “remedies that are available under the IDEA,” see id. at 1276. Furthermore, the Witte court noted that the relief sought for the plaintiffs injuries was “retrospective only” and that the relief available under the IDEA was not well-suited to remedying past instances of physical injury. See id. In Jason’s case, as in Plasencia, “the condition creating the damage has ceased,” and there is no equitable relief that would make Jason whole. Plasencia, 29 F.Supp.2d at 1152; cf. Padilla v. School Dist. No. 1, 35 F.Supp.2d 1260, 1265-66 (D.Colo.1999) (<HOLDING>). But see N.B., 84 F.3d at 1379 (finding it
holding that exhaustion was not required because the plaintiff had moved outside the school district and the administrative officer consequently lacked the authority to grant relief holding that plaintiffs cannot avoid the exhaustion requirement by limiting relief to money damages because otherwise future litigants could avoid the exhaustion requirement simply by asking for relief that administrative authorities could not grant holding district court lacked authority to order placement at a school not approved by the state holding that exhaustion is required even where the relief sought is not available in the administrative process holding exhaustion is required regardless of the relief offered through administrative procedures